Hiroto Imai and Mizue Kakiuchi of HoganLovells write:
The PPC has released its interim report last month and it is inviting public comments until 30 July 2024. Given that this is only an interim report and includes items that may have a significant impact on businesses and individuals, it is expected to be revised based on further discussions.
The items addressed in the interim report are as follows:
Protection of rights
（1） Proper handling of personal information, etc.:
- Biometric data with a high need of protection (e.g. people flow data and facial recognition images): currently, generally not considered as sensitive personal information.
- Prohibition of improper use: such use is not specifically categorised.
- Opt-out notification system (a system that allows the provision of personal information to third parties under certain conditions, if the privacy policy is notified to the PPC and made public, even when consent of the data subject is required in principle): considering imposing an obligation on data controllers to confirm the purpose of use, identity, etc. of the third party to which the information is provided.
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