Privacy Policy

Basic Policy on Personal Information Protection

Sanwa Kagaku Kenkyusho (hereinafter referred to as "our company") establishes this policy as a guideline for the measures used to protect the personal information we hold in order to fulfill our social responsibility as a company and to respond to the trust placed in us by our customers.

1. Compliance with Relevant Laws, Regulations, and Guidelines

Our company complies with the "Act on the Protection of Personal Information," as well as other laws and regulations, and guidelines, to protect personal information and handle it appropriately.

2. Acquisition of Personal Information

Our company acquires personal information by fair, lawful, and appropriate means.

3. Use of Personal Information

(1) Specification of Purpose of Use

When handling personal information, our company will specify the purpose of use as concretely as possible.

(2) Publication of Purpose of Use

When acquiring personal information, our company will, in principle, publicly disclose the purpose of use to the customer in advance. If not publicly disclosed, we will promptly notify the customer of the purpose of use or make it public.

(3) Change of Purpose of Use

When changing the purpose of use, our company will not exceed the reasonable scope related to the previous purpose of use. Additionally, we will notify the customer of the changed purpose of use or make it public.

(4) Limitation by Purpose of Use

When handling personal information beyond the necessary scope to achieve the specified purpose of use, our company will obtain consent from the customer in advance.

4. Management of Personal Data

(1) Ensuring the Accuracy of Data Content

Our company strives to keep personal data accurate and up-to-date within the scope necessary to achieve the purpose of use and to promptly dispose of the personal data when it is no longer required.

(2) Security Management Measures

Our company will take appropriate organizational, human, physical, and technical measures to prevent the leakage, loss, or damage of personal data, as well as for the overall security management of personal data.

(3) Supervision of Employees

When allowing employees to handle personal data, our company will provide necessary and appropriate supervision to such employees to ensure the safe management of such personal data.

(4) Supervision of Outsourcing Parties

When entrusting all or part of the handling of personal data to others, our company will provide necessary and appropriate supervision to the entrusted parties to secure the safe management of the personal data involved.

5. Provision of Personal Data to Third Parties

(1) Principle of Limiting Provision to Third Parties

Our company will use personal information only within the scope necessary to achieve the purposes of use notified to the customer. Furthermore, except where permitted by law, we will not provide personal data to third parties without obtaining prior consent from the customer.

(2) Provision to Third Parties through Opt-Out

For personal data (excluding sensitive personal information) provided to third parties, our company will, in advance, notify the individual concerned of the following items or make such items easily accessible to them, and will provide the personal data to third parties only when it has been reported to the Personal Information Protection Commission.

• Items of personal data provided to third parties
• Name, email address, name/address/phone number of the workplace, medical specialty, department affiliation, position, status, alma mater, sales performance, prescription status, etc.
• Methods of providing to third parties
• Orally, in writing, by electronic means, etc.
• Stop providing to third parties upon request from the individual
• Methods for accepting customer requests

(3) Joint Use

When jointly using personal information with third parties, our company will notify the customer in advance of the relevant information or make it easily accessible to them.

(4) Creation and Retention of Records Related to Provision to Third Parties

When providing personal data to third parties, we will create and retain records of such provision.

(5) Confirmation upon Receiving Provision from Third Parties

When receiving personal data, our company will accept it after confirming it by appropriate methods.

6. Disclosure of Matters Related to Retained Personal Data, Disclosure, Correction, and Suspension of Use of Retained Personal Data

(1) Notification of Matters Related to Retained Personal Data to Customers

Our company will make information regarding retained personal data accessible to customers, and will respond promptly to requests from customers.

(2) Notification of the Purpose of Use of Retained Personal Data

When a customer requests notification of the purpose of use of retained personal data that identifies them, our company will notify them promptly, except in certain cases.

(3) Correction of Retained Personal Data

If a customer requests a correction, addition, or deletion of their retained personal data on the grounds that it contains errors or is false, our company will promptly conduct the necessary investigation and, based on the results, will generally make the corrections as appropriate.

(4) Suspension of Use of Retained Personal Data

If a customer requests the suspension or deletion of the use of their retained personal data due to reasons such as unauthorized use without consent, and it is determined that the request is justified, our company will generally promptly suspend or delete the use of such data.

7. Disclosure of Personal Information

Our company will respond in good faith to requests from customers for notification of purposes of use, disclosure, correction, suspension of use, and cessation of provision of the personal information we hold, in accordance with the provisions of the applicable laws and regulations.

8. Complaints Handling Contact

Our company has established a dedicated contact point to address complaints and inquiries related to the handling of personal information and will respond to complaints from customers.

9. Organization for Personal Information Protection

Our company will appoint a personal information protection manager and establish an information management committee to oversee the execution of personal information protection.

10. Establishment of Personal Information Protection Regulations

To implement this policy, our company will establish personal information protection regulations and ensure that this policy and the regulations are thoroughly communicated to all executives and employees, while regularly auditing the implementation status and executing necessary improvements.

11. Education and Training

Our company will conduct education and training for all executives and employees regarding this policy and the personal information protection regulations to ensure appropriate management of personal information.

Important Matters Regarding the Handling of Personal Information by Our Company

1. Name of the Personal Information Handling Entity

SANWA KAGAKU KENKYUSHO CO., LTD.
35 Higashisotobori-cho, Higashi-ku, Nagoya, Aichi 461-8631, Japan
President & CEO Shusaku Isono

2. Purpose of Use of Personal Information

When using the personal information we hold, our company has established the following purposes of use and will handle personal information within that scope.

(1) Purpose of Use of Personal Information of Medical Professionals and Individuals Affiliated with Research Institutions Related to Medicine and Pharmacy

• Provision, collection, and examination of information regarding the proper use of pharmaceuticals, diagnostic agents, and other products handled by our company (hereinafter referred to as "pharmaceuticals, etc.").
• Provision, collection, and examination of information regarding the quality, safety, or efficacy of pharmaceuticals, etc.
• Collection, analysis, and communication of information regarding adverse effects, accidents, recalls, etc. of pharmaceuticals, etc., as well as their prior preparation.
• Collection, analysis, and communication of information regarding complaints and claims related to pharmaceuticals, etc.
• Collection, communication, and provision of information related to the research and development of pharmaceuticals, etc. (including the conduct of clinical trials and applications to domestic and international regulatory authorities).
• Collection, communication, and provision of information related to post-marketing surveys and clinical research regarding pharmaceuticals, etc.
• Investigation, examination, and response regarding the usage status, actual usage, and user requests of pharmaceuticals, etc.
• Provision and collection of information related to pharmaceuticals, etc.
• Identification of the delivery destinations of pharmaceuticals, etc., and improvement of communication networks.
• Conducting or supporting investigations and research in the fields of medicine and pharmacy, as well as seminars and study meetings.
• Provision, collection, and examination of information in the fields of medicine and pharmacy.
• Member authentication for Internet sites for medical professionals and communication with members.
• Notification and reporting to government agencies, industry associations, etc.
• Disclosure of compensation for requests related to lectures, manuscript writing, and consulting services regarding pharmaceuticals, etc.
• Establishment of means and environments to facilitate the smooth exchange of information.
• Collection and provision of information on the promotion of safety and health.
• Management of visit records to our company.

(2) Purpose of Use of Customers' Personal Information

• Examination, investigation, and response to the content of consultations, etc.
• Notification and reporting to government agencies, participating organizations, etc.
• Management of visit records to our company.

(3) Purpose of Use of Business Partners' Personal Information

• Matters Related to Business Transactions: Negotiation, Consultation, Review, Communication, Order Placement and Acceptance, Payment, and Response.
• Transfer of goods or services based on transactions.

(4) Purpose of Use of Personal Information of Voluntary Organizations, Local Stakeholders, and Other Interested Parties

• Matters Related to External Affairs: Communication, Consultation, Review, Negotiation, Provision of Information, Delivery and Receipt of Materials, and Response.
• Joint operations management and related communication, consultation, examination, information provision, transfer of distributed materials, and responses.

(5) Purpose of Use of Personal Information of Job Applicants and Candidates

• Provision and communication of a range of information related to recruitment.
• Examination and decision on hiring.
• Collection and provision of information for the employment and personnel management of selected candidates.

(6) Purpose of Use of Personal Information of Executives, Employees, Their Families, and Former Employees

• Notification and reporting to government agencies and industry associations.
• Management of work attendance, payment of salaries and bonuses, personnel matters, evaluation, capability development, welfare, health and safety, and internal communications.
• Communication and provision of information to labor unions, welfare mutual aid associations, health insurance unions, corporate pension funds, defined contribution pensions, employee stock ownership plans, related companies, and insurance companies.
• Communication and distribution of materials related to social activities such as "Kenyuu-kai".
• Publication of images and other materials for information sharing both inside and outside the company.
• Response for information sharing within the company and information disclosure to external parties.
• Communication in emergency situations.

(7) Purpose of Use of Personal Information of Customers Using Our Service Counters, etc.

• Examination, investigation, and response to the content of consultations and communications.
• For the purpose of identity verification, including review, investigation, and response.
• Response and investigation regarding side effects, incidents, recalls, etc., related to pharmaceuticals and related products.
• Provision of information related to pharmaceuticals and related products, and response to after-service matters.
• Communication and provision of information to manufacturers, sellers, and healthcare professionals related to pharmaceuticals and related products.
• Notification and reporting to government agencies and participating organizations.

* Please note that we record phone conversations when you engage with our company's contact center to ensure we have an accurate understanding of the details of your inquiry.

Regarding the personal information we hold, we may provide it to our business partners and group companies in order to achieve the above-mentioned utilization goals. However, at your request, we can suspend such provision.

3. Joint Use of Personal Information

Our company will jointly utilize personal information and personal data as follows.

（1）Joint use of personal information and personal data of healthcare professionals stored in the Nihon Ultmarc INC. Medical Database (MDB) with other pharmaceutical companies, pharmaceutical wholesalers, etc.

• The entity responsible for the management of personal information and personal data:
  Nihon Ultmarc INC.
• Purpose of use, scope of joint users, items for joint use:

* Please refer to the website for details, as the operations are based on the Medical Database (MDB) managed by Nihon Ultmarc INC.

Nihon Ultmarc INC. Website (The link is to a Japanese site.）

(2) Joint use of personal information and personal data of healthcare professionals, etc., included in records related to clinical trials involving our company and companies that collaborate on pharmaceutical research and development.

• Entity responsible for the management of personal information and personal data
  SANWA KAGAKU KENKYUSHO CO., LTD.
• Purpose of use
  Collection, transmission, and provision of information related to the research and development of pharmaceuticals (including the implementation of clinical trials and applications to regulatory authorities both domestically and internationally).
• Scope of joint users
  Partner companies related to research and development.
• Items to be shared
  Name, gender, name of the workplace facility, workplace address, workplace telephone number, email address, medical department, affiliated department, position, job title, year of graduation, graduating school, date of birth, year of physician license acquisition, physician license number, qualifications such as board certifications, work history, and affiliated academic societies, etc.

4. Contact Point for Complaints and Requests for Disclosure, etc.

The dedicated contact point for complaints, requests for disclosure, suspension of use, and provision suspension, as well as other inquiries, is as follows

5. Method for Filing Complaints and Requests for Disclosure, etc.

Complaints and requests for disclosure related to personal information will be received via telephone or email (form mail). We will then contact you directly by phone or other means. At that time, we will explain the documents required for your request. To provide information regarding the requested items, a postage stamp equivalent to the cost of postal charges (first-class standard, registered mail, and delivery confirmation) will be required.

* Please note that we cannot accept requests made in person at our office, and we appreciate your understanding in this matter.

6. Others

Our company is a certified business entity of the Japan Pharmaceutical Manufacturers Association, which is recognized by the Minister of Health, Labour and Welfare as a designated personal information protection organization. This association accepts complaints and inquiries regarding the handling of personal information by its designated businesses.

7. Review of Personal Information Protection Policy

In order to ensure the proper handling of personal information, our company will review and continuously improve this basic personal information protection policy as needed.

April 1, 2005
Revised on June 13, 2007
Revised on August 10, 2012
Revised on May 30, 2017
Revised on April 1, 2022