Personal Information Protection Policy

Personal Information Protection Policy

RGF Talent Solutions Japan K.K. ("RGF") provides executive search and recruiting services in Japan. In operating its business, RGF must handle a great deal of personal information concerning candidates, clients, and employees. Therefore, RGF has established this Policy along with a personal information management system through which RGF, as a company, commits to meeting its responsibility in protecting personal information.

Policy 1: RGF will, to the extent possible, specify the purposes for utilizing the personal information, and will properly handle the personal information within the scope necessary to achieve such purposes. RGF will take measures to ensure the prevention of personal information being used other than for the intended purposes.

Policy 2: RGF will obtain personal information only through legitimate and appropriate means.

Policy 3: RGF will not provide any personal information of any individual to a third party without the consent of that individual.

Policy 4: In managing personal information, RGF will make efforts to take all necessary and appropriate measures to ensure the prevention and correction of any leakage, loss or damage of the personal information, as well as for other safety management factors.

Policy 5: In handling personal information, RGF will make efforts to ensure that the individual who has provided the information shall be properly involved in the handling process, and to keep the personal information accurate and updated to the extent possible.

Policy 6: RGF will comply with laws and regulations pertaining to the protection of personal information, and will establish, review continuously, and comply with the internal rules pertaining to the protection of personal information.

Policy7: RGF will establish a contact window to correspond to complaints and consultations concerning the protection of personal information and make efforts to properly respond to such complaints and consultations.

Struan McKay, CEO

RGF Talent Solutions Japan K.K.

RGF Talent Solutions Japan K.K.(“RGF") shall uphold this privacy policy, shall respect the privacy of companies, affiliated companies, associations, etc., that use the services provided in accordance with this privacy policy ("Services") (“Service Using Companies, etc.”) and each person ("Candidate") who uses the services and shall handle the personal information (as defined below) of all Users with the utmost care in its management thereof.

Please refer to “Processing of Personal Data of Persons within the EEA (Attachment)” for users in EEA (European Economic Area, European Economic Area).(Link)

Personal information

Personal information is the information of a Candidate as an individual, which can identify the Candidate based on the name, address, telephone number, e-mail address, educational institution, or other descriptions, etc. which constitutes such information. In addition, any information which may not identify the Candidate solely by itself but can easily be cross-referenced with other information to identify the Candidate as a result, is also included in the scope of personal information.

Purposes of use of personal information

RGF shall use personal information only for the following purposes, and shall not use any personal information beyond these purposes of use:

• Provision of information and services concerning job referrals, employment, career change, and Professional Resourcing Service (hereinafter “PRS”).

• Provision of personal information to Service Using Companies, etc., based on Candidates’ consent/application.

• Listening in on opinions or requests aimed at confirming Candidates’ situation after employment or dispatching, and improving services.

• Confirmation of the candidate’s application and commence as well as receiving notices from Service Using Companies during and after the period of service provision.

• Statistically processing and analyzing information for publication on websites and other media.

• Development and marketing of new services.

• Advising and proposing recruitment plans for companies seeking workers.

• Managing inquiries, consultations and complaints, and/or resolving disputes.

• Hiring operations for RGF.

• Making contact through generally shared information, such as publications and websites.

Voluntary nature of providing personal information

Although it is not necessary to provide all of the items asked for, if a Candidate fails to answer necessary question(s), such Candidate may not be able to obtain the services RGF provides.

Disclosure of personal information to the third party

RGF, as a recruiting agency, will provide personal information (limited to Company name, position title, job description etc.) obtained from the Candidate or from public source, after examining the Candidate’s requests and adequacy, by sending or carrying the document to contracted companies who have agreed to the articles of properly handling personal information

However, personal information may be disclosed without Candidates’ consent within the confines of applicable laws and regulations when:

• A) The Candidate is considered detrimental to the third party.

• B) The provision of personal information is especially necessary for improving public hygiene or promoting the sound growth of children and it is difficult to obtain the consent of the Candidate.

• C) The provision of personal information is necessary for cooperating with a state institution, a local public body, or an individual or entity entrusted by such an institution or body to execute operations prescribed by law and obtaining the consent of the Candidate might impede the execution of such operations.

• D) A court, prosecutor’s office, police department, or any other institution with corresponding authority requests disclosure of the Candidate’s personal information.

• E) The Candidate him/herself explicitly requests the provision or disclosure to the third party.

• F) The disclosure and provision of personal information is allowed by laws and regulations.

• G) The provision of personal information occurs as a result of business succession in a merger or otherwise and is utilized within the purpose range set before the succession.

Outsourcing of personal information handling process

RGF may outsource partial or all of the personal information handling duties. RGF shall be responsible for the handling of personal information by the outsourcing contractor.

Use of statistically-processed data

RGF may, based on the provided personal information, create statistical data which shall be processed in a manner that cannot identify any individual. RGF may, without restriction, use statistical data that cannot identify individuals.

Disclosure etc. of personal information

In the event a Candidate requests for a notice, disclosure, correction, addition / deletion, suspension, or elimination for the use of Candidate’s personal information or suspension of provision to the third party, RGF shall take prompt actions according to its internal regulations. However, in cases where complying with such requests might impede necessary operations, RGF may not be able to accommodate the request for disclosure, correction, deletion, suspension or elimination of information.

Accuracy of personal information

RGF shall make efforts to accurately process the personal information provided. However, Candidates are to be responsible for ensuring that the personal information they provide is accurate and up-to-date.

Restrictions on acquisition of sensitive personal information

RGF, as a general rule, shall not obtain any Candidate’s personal information which containing any of the following information unless the personal information has been provided by the Candidate himself/herself:

• A) Information relating to personal philosophy, belief or religion;

• B) Information relating to race, ethnic background, family background, domicile (except for information on the prefecture where the Candidate is located), physical or mental disability, criminal record or other matters that may cause social discrimination;

• C) Information relating to the right to organize, or any acts of collective bargaining or other collective actions as a worker;

• D) Information relating to participation in acts of mass demonstration, exercising of petition rights or other political rights;

• E) Information relating to health and medical conditions or sex life.

Personal Information Protection Manager

Personal Information Protection Manager, RGF Talent Solutions Japan K.K.

Modifications to Privacy Policy

Unless otherwise stated in laws and regulations, etc., RGF shall be entitled to modify this Privacy Policy as needed.

Inquiries

Please contact “rgfjp.information@rgf-professional.com” for any inquiries regarding the handling of personal information, and for requests regarding personal information for notice of purpose of use, or disclosure, correction, addition or deletion or discontinuation of use, erasure or discontinuance of provision to a third party.

(Supplementary Provisions)

Established and implemented on Oct 1, 2014

Revised on January 1, 2018

Revised on April 1, 2018

Revised on October 1, 2018

Revised on June 1, 2019

*RGF Talent Solutions Japan K.K. is accredited as "privacy-mark" licensed operator