SAJP Privacy Policy (June 26, 2018)
The Stockholm Association for the Japanese Language Proficiency Test (SAJP) shall comply with the EU General Data Protection Regulation (GDPR) and applicable national laws in Sweden (SNL) in connection with the provision of any of the services that SAJP provides together with the Japan Foundation (JF) in order to plan and execute the Japanese Language Proficiency Test (JLPT) for the benefit of test examinees (TE), mainly from countries in the European Economic Area (EEA), and therefore hereby establishes this Privacy Policy in order to appropriately process the personal data and other data of examinees mainly from countries in the EEA. This Privacy Policy of coure also applies to examinees from countries outside of the EEA.
- Processing Personal data, etc.
(1) Definitions
“Personal data” means any data relating to an identified or identifiable natural person, including, without limitation, names, addresses, dates of birth, telephone numbers, e-mail addresses, and any other information collected in connection with providing the JLPT.
“Processing” means any operation or set of operations which is performed on personal data, etc. or on sets of personal data, etc., whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
(2) Purpose of use of personal data, etc.
The SAJP will process the TEs’ personal data and share personal data with the JF in order to provide, improve and develop the JLPT.
In the case of processing the TEs’ personal data for purposes other than the above, the SAJP will notify TEs in advance of such new purposes of use and other matters as required by applicable laws.
By manifesting their intention to consent to this Privacy Policy, TEs will be deemed to have consented to the processing of their personal data by the SAJP within the scope of the above purpose of use (JLPT), and the SAJP will process the TEs’ personal data based on such TEs’ consent; provided, however, that TEs may withdraw such consent at any time. Even in that case, this will not affect the lawfulness of processing performed pursuant to consent before the TEs’ withdrawal thereof.
The personal data that TEs are to provide is necessary in order for the SAJP and the JF to provide the JLPT to the TEs, and there may be cases in which TEs who have not provided such data will be unable to use the Services provided (in principal the JLPT).
(3) Retention Period
The SAJP will retain the TEs’ personal data as long as the SAJP and the JF requires such data for achieving the purpose of use specified above.
(4) Transfer
The SAJP needs to share the obtained personal data with the JF headquarter in Japan and the Embassy of Japan to Sweden, and may provide such data to third parties such as cloud vendors and outside contractors of the SAJP and/or the JF, etc., to implement the purpose of use specified above. Countries located outside the EEA (including, without limitation, Japan, the same shall apply hereafter) are among the third parties to whom the SAJP and the JF will disclose the TEs’ personal data, and the TEs shall be deemed to have consented to the following matters by consenting to this Privacy Policy:
(a) In the case that the country in which the third party is located is outside the EEA, such country does not have the same data protection laws as EEA member countries, i.e., many of the rights provided to data subjects in the EEA may not be given;
(b) The TEs’ personal data will be provided and processed for the purpose specified above; and
(c) The TEs’ personal data will be provided to third parties located outside the EEA.
In addition to the above, in the case that the SAJP provides the TEs’ personal data to a third party located in a country outside the EEA, the SAJP will ensure that adequate measures such as standard contract clauses based on the GDPR are taken concerning the protection of the TEs’ personal data.
(5) Rights of TEs
The TEs may request from the SAJP access to, rectification or erasure of, and restriction of processing of their personal data, may object to the processing of the TEs’ personal data, and may request data portability. The SAJP accepts such TEs’ requests at the contact point set forth in “3. Contact” below.
The SAJP may refuse the TEs’ requests if the SAJP deems that there is no basis for such TEs’ requests or if they are deemed excessive.
The TEs may raise objections with the data protection authorities having jurisdiction over the location of the TEs’ domicile with regard to the processing of their personal data.
- Safety Management Measures
In order to protect from unauthorized access to personal data, loss, etc. of personal data, taking into account the type of personal data, the degree of sensitivity and the degree of economic influence and mental harm caused to TEs in the case of a personal data breach, the SAJP comprehensively evaluates and judges the risks of personal data breaches, implements appropriate personal, organizational and technical safety management measures based on the risk of a personal data breach, if necessary, checks such safety management measures, sets up a process for correction, and constantly strives to improve security.
The SAJP shall strive to appropriately manage personal data by restricting the entry of outsiders into the offices which are processing personal data, conducting educational awareness activities for all officers and employees involved in the protection of personal data, and placing a manager in charge for each division processing personal data.
- Contact
In the event of TEs having any questions or concerns regarding this Privacy Policy or the processing of personal data by the SAJP or having any requests concerning the access to, rectification of, erasure of, or restriction of processing of personal data, or regarding data portability, please contact the SAJP.
The contact information for the SAJP is as follows:
The Stockholm Association for the Japanese Language Proficiency Test
Att: SAJP Chairperson
c/o Department of Asian, Middle Eastern and Turkish Studies
S-106 91 Stockholm
Sweden
E-mail: info@sajp.info
The Japan Foundation
4-4-1 Yotsuya, Shinjuku-ku, Tokyo 160-0004, Japan
Tel: +81-(0)3-5369-6051 / Fax: +81-(0)3-5369-6031
E-mail: soumu@jpf.go.jp