Protection of Personal Information

The HGST Health Insurance Association (hereinafter “HGST”) conducts various healthcare businesses for the purpose of providing insurance benefits and maintaining as well as promoting better health of insured persons and dependents (hereinafter “enrollees”). HGST strives to properly collect, use, and protect the personal information by defining this Privacy Policy to earn the trust of every enrollee in the course of executing these healthcare businesses.

HGST Health Insurance Association Policy on the Protection of Personal Information
(Privacy Policy)
The HGST Health Insurance Association promotes the following initiatives from a stance of properly protecting the personal information of each enrollee (hereinafter “personal information”).
  1. HGST has put in place the proper measures to protect the personal information collected from enrollees in an effort to prevent any leak, loss, damage, or unauthorized access to the personal information of enrollees.
  2. HGST only uses personal information provided by enrollees for the purposes believed to benefit every enrollee, such as maintaining and promoting better health. HGST also only uses individual numbers for the designated purposes and range stipulated by the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedures.
  3. HGST never discloses personal information about an enrollee to a third party without prior consent. Moreover, the HGST never discloses personal information which includes individual numbers (hereinafter “personally identifiable information”) regardless of whether an enrollee gives consent, except when said disclosure is stipulated in the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedures.
    However, personal information which is not personally identifiable information may be shared with a third party without the prior consent of an enrollee if said disclosure is Article 27, Paragraph 1 of the Act on the Protection of Personal Information (Law No. 57, May 30, 2003).
  4. HGST provides education and raises awareness about the protection of personal information in all of its employees and appoints an officer responsible for handling personal information in an effort to properly handle any and all personal information.
  5. HGST reviews and enhances any outsourcing operations to ensure an even higher level of personal information protection. When entering into any outsourcing agreement, HGST carefully evaluates the qualifications of each outsourcer and makes certain even the terms and conditions of contracts provide the utmost protection of personal information.
  6. HGST strives to ensure the personal information of enrollees is as up-to-date, accurate, and protected as possible. Enrollees may make inquiries, corrections or any other such requests regarding their personal information by contacting HGST customer service. HGST will promptly respond to said requests within a reasonable range.
  7. HGST complies with all laws, regulations and other standards related to the handling of the personal information of enrollees and consistently revises and improves the terms and conditions of this privacy policy.
Customer Service
HGST Health Insurance Association
TEL: 03-6380-1635 
Email: info@hgst-kenpo.jp
Business hours: Weekdays 9:30 A.M. to 12:00 P.M.; 1:00 P.M. to 6:00 P.M.
Disclosure of Personal Information Collected by HGST and Its Purpose of Use
The HGST Health Insurance Association (hereinafter “HGST”) creates a personal information database and uses personal information to render health insurance services collected from (1) personal information included on various notifications and application forms submitted by insured persons and family dependents (hereinafter “enrollees”), (2) personal information included on statements of medical expenses (hereinafter “health insurance claims”) billed by healthcare providers and other medical institutions for medical care provided to enrollees, and (3) personal information included in the health checkup results data from medical examinations undergone by enrollees.
HGST uses personal information for the purpose of either providing insurance benefits to enrollees for illnesses, injuries, or deaths not caused by occupational accidents as well as childbirth, or executing operations necessary for maintaining and promoting better enrollee health as provided for in the Health Insurance Act.
HGST services require a tremendous amount of trust from enrollees as a health insurance association handling a large volume of medical data from health insurance claims to medical examination results as well as other personal information. Therefore, the Ministry of Health, Labour and Welfare published more detailed guidelines advising clearly defined purposes to limit the use of personal information.
HGST shall handle the personal information collected in Attachment 1 in accordance with the usage purposes outlined in Attachment 2 as a general rule. The purpose and method for using personal information is disclosed below.
Furthermore, HGST never uses personal information in its possession for any other purpose than running its healthcare businesses.
  1. Applicable Notification and Application Forms
    1. HGST has configured a master database (hereinafter “master data”) including an enrollee ledger and stores data on computers for operational processes to use throughout the entire health insurance association for input and processing of health insurance card numbers, names, dates of birth, genders, addresses, monthly remuneration and other items included in applications for eligibility as an insured person or dependent change notifications when individuals enroll in the health insurance association.
    2. HGST issues health insurance cards after verifying applications for eligibility as an insured person and dependent change notifications.
    3. HGST executes certification processes according to certificates of taxation and exemption of local taxes, copies of student identification cards, income statements and various other discretionary materials when an insured person submits a dependent change notification.
    4. HGST requires insured persons to return health insurance cards when submitting a notification of forfeiture of eligibility, which are verified and stored for a fixed period of time before disposal.
    5. HGST updates the data registered as master data according to applicable change (correction) notifications to update or add information to the master data.
    6. HGST correlates data on benefits, health insurance claims, health examination and other relevant data using the master data to verify benefit payments and other processes, to identify persons related to notifications on medical care costs and various other health insurance businesses, and to contact enrollees.
    7. HGST may contact individuals using the address, name or any other contact information included on notifications or in the master data as necessary even after said individual loses eligibility as an insured person of the health insurance association.
    8. HGST answers inquiries about qualification or forfeiture of eligibility and other such health insurance-related healthcare questions from healthcare providers, other insurers, including municipalities and pension offices, using personal information such as health insurance card numbers, names, dates of birth, genders, dates of qualification, or dates of loss of qualification, after verifying the identity of the person making the inquiry.
    9. HGST may ask other insured persons or third parties about health insurance card numbers, names, dates of birth, genders, dates of certification or loss of qualification or other information in the master data to make adjustments of duplicate benefits of other insured persons or healthcare providers if any discrepancies arise, such as examinations after an individual loses eligibility as an insured person.
    10. HGST incorporates data from notifications on the calculation basis and monthly changes into the master data to charge insurance premiums, including adjusted insurance premiums and long-term care insurance premiums. In addition, HGST requests employers submit salary and bonus ledgers and other documentation for review when submitting a notification.
    11. HGST provides health insurance card numbers, names, dates of birth, genders, and addresses included in the master data about individuals applying for a physical examination to contract healthcare providers to use when sending results from the examination.
    12. HGST provides health insurance card numbers, names, genders, and addresses included in the master data about individuals using health service options to contractors to use for various purchasing applications.
  2. Cash Payments and Other Benefit Application Materials
    1. HGST enters data on computers for business processing and reviews application details to make proper payment decisions.
    2. HGST enters data to store payment records for use when reviewing applications thereafter.
    3. HGST may ask a third-party insured person about health insurance card numbers, names, dates of birth and other information in the master data about individuals requesting childbirth and childcare lump-sum allowances or dependents’ childbirth and childcare lump-sum allowances when necessary for adjusting duplicate benefits of other insured person to make payment decisions.
    4. HGST responds to inquiries about whether a request was made for childbirth and childcare lump-sum allowances or dependents’ childbirth and childcare lump-sum allowances from other insured persons by providing information about applications and benefits after verifying the identity of the person making the inquiry.
    5. HGST reviews health insurance claim data of individuals requesting injury or illness allowance and asks the physician in charge for verification or evaluation, the status of medical treatments, and any other applicable information as necessary to make payment decisions.
  3. Certificate of Medical Remuneration (Health Insurance Claims)
    1. HGST stores images and data of health insurance claim requests by the Health Insurance Claims Review & Reimbursement Services on its computers for business processing to use in healthcare businesses.
    2. HGST reviews health insurance claim data and requests a secondary evaluation by the Health Insurance Claims Review & Reimbursement Services for any questions arising about a claim.
    3. As part of this request for a secondary evaluation, HGST shares the name of the health insurance association, the health insurance card number, name, date of birth, date of loss of qualification, the date on which medical care was provided and other relevant information with the healthcare provider for confirmation if a question arises about an exam after the individual loses their qualification as an insured person.
    4. As part of a review of whether there are public expenditures of patients expected to pay high-cost medical expenses or medical cost subsidies from a municipality, HGST shares the name of the health insurance association, the health insurance card number, name, date of birth, and other relevant information with the healthcare provider for confirmation.
    5. HGST uses health insurance claim data to analyze medical costs and ensure no billing errors of the health insurance association as well as to provide post-health guidance after physical examinations, and to identify candidates for education to prevent lifestyle diseases.
    6. HGST uses health insurance claim data to identify and provide guidance to enrollees who have undergone examinations at several healthcare providers in the same month.
    7. HGST uses health insurance claim data to make decisions on payments of high-cost medical expenses and benefits, such as co-payment reductions, additional aggregated high-cost medical expenses, and additional family medical expenses.
    8. HGST refers to health insurance claim data to make payment decisions about injury and illness allowances.
    9. HGST refers to health insurance claim data to make payment decisions about therapies and other medical treatments performed by judotherapists as well as medical costs for family dependents.
    10. HGST refers to health insurance claim data to make payment decisions about funeral expenses of an insured person or family.
    11. HGST responds to requests for disclosure of health insurance claims by providing relevant data for said health insurance claims.
      Moreover, HGST only discloses information to approved parties in accordance with disclosure rules pertaining to disclosure requests.
    12. HGST provides health insurance claim data to contractors to notify enrollees of medical care costs.
    13. HGST submits copies of health insurance claims of relevant patients for any medical care provided due to traffic accidents or actions of a third party to non-life insurance companies and administrative contractors handling reimbursement of medical costs.
    14. HGST outsources Japanese translations of statements of medical care costs and other documentation received from healthcare providers overseas to an external translation contractor.
    15. HGST sends a copy of health insurance claims and applications including some of the details in the course of applications to joint projects to pay high-cost medical expenses run by the National Federation of Health Insurance Societies (Kenporen) to receive subsidy grants.
  4. Health Checkups
    1. HGST outsources health checkups to medical contractors.
    2. HGST receives the numerical result data from the medical contractor and notifies the patient of said results. HGST also uses the results data to provide post-health guidance after the examination and identify candidates for education to prevent lifestyle diseases.
    3. The HGST Health Insurance Association provides health checkups in cooperation with employers. Therefore, HGST contacts every employer about the numerical results of health checkups of insured persons (employees) as a general rule, and HGST and the employer both store a copy to help in the health management of insured persons.
    4. HGST saves result data from health checkups as master data to compare with future data for reference in the provision of health management services and health guidance.
  5. Execution of Other Healthcare Businesses
    The HGST Health Insurance Association uses health insurance card numbers, names and addresses in the master data when conducting various healthcare businesses.
  6. Human Resource Data on Officers and Employees, HGST Committee Member List, and a List of Health Insurance Representatives at Each Business Establishment
    1. HGST carefully stores all materials about the appointment and hiring of HGST officers and employees after use.
    2. HGST carefully stores all materials about the remuneration of HGST officers and employees to use for tax withholdings and other such processes.
    3. HGST uses the HGST Committee Member List when contacting members and directors about Board of Directors meetings and other matters.
    4. HGST uses the list of names of health insurance representatives at each business establishment, at the Health Management Promotion Committee, and in other business-related liaison work.
  7. Personally Identifiable Information
    “Personally identifiable information” refers to personal information, including individual numbers (My Numbers) or other numbers, codes and symbols used as an alternative to individual numbers, excluding certificate of residence codes.
    The Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures defines the usage scope of personally identifiable information, such as the sharing of information between parties involved in administrative processes of government bodies. For example, local municipalities provide information on taxation and exemption of local taxes to health insurance societies for the certification of dependents. Personally identifiable information cannot be used for any purpose other than the specific purposes within the usage range stipulated by the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures.
    In addition, any use outside the usage scope stipulated in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures must mask, delete or take other measures to redact individual numbers from personally identifiable information.
  8. Storage Management, Disposal and Deletion of Personal Information
    1. HGST document management regulations define rules for warehouse storage of any personal information included in various notifications, applications, health insurance claims, and other paper documents for a prescribed number of years after data entry and restrict anyone from taking said documents out of storage unless necessary for verification or other such processes.
    2. HGST also properly stores personal information in non-paper mediums according to operation management rules related to the storage on non-paper mediums.
    3. HGST shreds paper documents containing personal data which has passed the prescribed storage period or is no longer necessary after processing into small illegible pieces and outsources disposal of a large quantity of personal data to contract processors which dissolve said documents into pulp.
    4. HGST disposes or returns computers and other magnetic storage media by first rendering data unreadable using a data erasing software.
Disclosure of Personal Information to Third Parties
A health insurance association is deemed to have been granted full implied consent for the use of personal information when no explicit objection or reservation is raised by the insured person or other concerned parties in its position under Notification No. 0414-(18), “Guidance on Proper Handling of Personal Information at Health Insurance Societies,” issued on April 14, 2017 by the Director of the Health Insurance Bureau of the Ministry of Health, Labour and Welfare Health Insurance Bureau for purposes beneficial to insured persons and other concerned parties or in cases where changes to current methods of notification on medical care costs or other such information impose an unreasonable burden on the health insurance association while obtaining explicit consent would also not necessarily be reasonable from the point of view of the insured person, which applies to the provision below.
  1. Disclosure of Personal Information to Third Parties (Scope of Full Consent)
    [Usage Purposes]
    1. To provide notifications on health care costs for a single household
    2. To provide payments for high-cost medical expenses and additional benefits without relying on applications from individuals
    3. To provide payments for childbirth and childcare lump-sum allowances and other various payments and additional cash benefits
    4. To provide payments for influenza vaccine and other healthcare business subsidies to insured persons for family members
  2. Items, Procedures and Methods for Disclosure of Personal Information (Personal Data) to Third Parties
    Usage
    Purposes
    Item of Personal Information for Disclosure to Third Parties Procedure and Method of Disclosure
    1 Names of patients, dates of treatments, payment period, treatment classifications or types of benefits, days, total medical care costs, amount of health insurance coverage, out-of-pocket costs, names of healthcare providers rendering treatments, amount of statutory benefits, amount of additional benefits, and payment dates Disclosed as statements of medical care costs every month on the HGST Health Insurance Association website
    2 and 3 Codes, numbers, names of individuals, names of the type of cash benefits, and amounts of payments Disclosed to the person in charge at the employer
    4 Codes, numbers, names of individuals, names by type, and amounts of payments Disclosed to the person in charge at the employer
  3. Handling of Anonymized Data
    “Anonymized data” refers to information related to individuals collected by anonymizing data to remove any personally identified information and ensure the personally identifiable information cannot be recovered to identify an individual.
    Health insurance societies continuously create anonymized data for healthcare businesses, epidemiological surveys, and other such operations in order to provide said data through electronic means of communication to contractors which analyze health insurance claims. The anonymized data created for provision includes genders, dates of birth, health insurance eligibility, such as enrollment periods, withdrawal periods, and the classifications of the insured persons and family, histories of treatments in certificates of medical remuneration, and the histories of general medical checkups as informational items. This anonymized data never includes any personally identifiable information.
  4. Procedures to Cease Disclosures to Third Parties
    1. Insured persons and other individuals may request the HGST Health Insurance Association obtain explicit consent in advance for any usage purposes which the individual does not feel comfortable granting implicit consent.
    2. If the insured person or other individuals do not express the above intention to cease disclosure, HGST deems that it has received full consent for the usage purposes it has announced.
    3. The insured person and other individuals may decide to grant full consent or indicated reservations about disclosing an item at any time.
    Please contact HGST customer service using the contact information below if you would like to cease disclosure of any items.
    Customer Service
    HGST Health Insurance Association
    TEL: 03-6380-1635 
    Email: info@hgst-kenpo.jp
    Business hours: Weekdays 9:30 A.M. to 12:00 P.M.; 1:00 P.M. to 6:00 P.M.
Joint Use of Personal Information: (1) Subsidy Projects Related to Payment of High-cost Medical Expenses
The HGST Health Insurance Association uses personal information (personal data) it has collected in the joint projects outlined below.
In addition, Article 27.5.3 of the Act on the Protection of Personal Information stipulates an entity or business operator receiving such personal information (personal data) shall not be deemed a third party and may disclose such personal information (personal data) without the prior consent of the individual in cases in which (1) personal data used jointly, (2) the items of the personal data used jointly, (3) the scope of the joint users, (4) the purpose for which the personal data is used by them, and (5) the name of the individual or business operator responsible for the management of the personal data is, in advance, notified to the person or put in a readily accessible condition for the person.
  1. Items for Joint Use of Personal Information (Personal Data)
    (1) Certificates of medical remuneration including certificates of pharmaceutical remuneration (hereinafter “health insurance claims), (2) data or written documents for summary statements of subsidy applications recording items such as patient names, genders, insured persons or family dependents, in-patient or out-patient care, dates of treatments, and the amounts of said health insurance claims, in addition to all other items of data included in health insurance claims
  2. Persons or Entities Jointly Using Personal Information
    • Kenporen, subsidy project groups, employees in charge of high-cost medical expenses
    • Contractors of Kenporen (ICT and healthcare promotion divisions and partner companies of the Japan Productivity Center)
  3. Joint Usage Purposes
    Subsidy projects related to payment of high-cost medical expenses
  4. Officer Responsible for Personal Information Management
    • HGST Health Insurance Association
      (Address) 2F Yoyogi East, 5-23-5 Sendagaya, Shibuya-ku, Tokyo
      (Board chairperson) Reiji Suzuki
      (Manager) Managing director
    • National Federation of Health Insurance Societies
      (Address) 1-24-4,Minami-aoyama,Minato-ku,Tokyo
      (Chairman) Shunichi Miyanaga
      (Manager)  Support Dev General manager
  5. Inquiries
    Customer Service
    HGST Health Insurance Association
    TEL: 03-6380-1635 
    Email: info@hgst-kenpo.jp
    Business hours: Weekdays 9:30 A.M. to 12:00 P.M.; 1:00 P.M. to 6:00 P.M.
Joint Use of Personal Information (2) Personal Information Used Jointly with Employers
The HGST Health Insurance Association uses personal information (personal data) it has collected in the joint projects outlined below.
In addition, Article 27.5.3 of the Act on the Protection of Personal Information stipulates an entity or business operator receiving such personal information (personal data) shall not be deemed a third party and may disclose such personal information (personal data) without the prior consent of the individual in cases in which (1) personal data used jointly, (2) the items of the personal data used jointly, (3) the scope of the joint users, (4) the purpose for which the personal data is used by them, and (5) the name of the individual or business operator responsible for the management of the personal data is, in advance, notified to the person or put in a readily accessible condition for the person.
  1. Items for Joint Use of Personal Information (Personal Data)
    1. Personal information about individuals including necessary information about dependents such as names, genders, dates of birth, employee numbers, affiliations, positions, addresses, telephone numbers, standard monthly remuneration, standard amount of bonuses, business email addresses, and certifications as a dependents
    2. Information about regular health check-ups, physical examinations, and other general health examinations provided by the HGST healthcare business including codes, numbers, names, dates of birth, genders, age, addresses, telephone numbers, and email addresses of patients as well as the names of employers, employee codes, dates of heath examinations, dates of reservations for health examinations, names of healthcare providers, items included in the health examinations, numerical results of healthcare examinations, diagnoses, questions asked by physicians, and details of any health guidance
  2. Persons or Entities Jointly Using Personal Information
    • HGST employees
    • HR managers of employer
    • Medical examiners of employer
    • Industrial physicians
    • Contractors
  3. Joint Usage Purposes
    1. Smooth and precise execution of the HGST operations, such as certifying or revoking eligibility, benefits payments, and healthcare businesses stipulated for health insurance societies by the Health Insurance Act
    2. HGST and employer activities for health promotion and prevention of onset and progression of illnesses through aftercare, health guidance, consultations and other measures based on health examination results of insured persons as well as
      evaluations and analyses after taking measures to enhance the effectiveness of projects conducted with employers
  4. Officer Responsible for Personal Information Management
    • HGST Health Insurance Association
      (Address) 2F Yoyogi East, 5-23-5 Sendagaya, Shibuya-ku, Tokyo
      (Board chairperson) Reiji Suzuki
      (Manager) Managing director
    • Employers and General HR managers
  5. Inquiries and Feedback
    Customer Service
    HGST Health Insurance Association
    TEL: 03-6380-1635 
    Email: info@hgst-kenpo.jp
    Business hours: Weekdays 9:30 A.M. to 12:00 P.M.; 1:00 P.M. to 6:00 P.M.
Procedures for Disclosure or Correction of Personal Data or Termination of Use
Anyone who would like to request disclosure or correction or stop use of personal data collected by HGST may acquire, fill out, and submit the designated HGST application form according to the handling requirements related to the disclosure or correction of personal data or termination of use.
Specific Procedures
  1. Acquire a Request for Disclosure of Personal Information Collected by HGST to file a request for disclosure of personal information or acquire a Notification of Correction/Termination of Use of Personal Information Collected by HGST to file a request to correct or terminate the use of personal information.
  2. Fill in the necessary items.
  3. Prepare the necessary documents to attach. Please ask HGST about the necessary document attachments.
  4. Submit the application form and other materials to HGST.
HGST considers the convenience of everyone filing requests or notifications to make application processes as simple as possible for individuals. The HGST responds to any requests or notifications in writing. As a general rule, HGST will respond to a request for disclosure by disclosing the information regardless of the reason. However, HGST may refuse to disclose information in part or in whole if the disclosure may harm the assets or other interest of a third party, if it may significantly inhibit the proper execution of HGST operations, or if the HGST does not have the personal data requested for disclosure. In this case, HGST will immediately notify the individual of the reason in writing.
Requests for Disclosure of Certificates of Medical Remuneration (Health Insurance Claims)
HGST discloses certificates of medical remuneration (health insurance claims) in accordance with rules on disclosure of certificates of medical remuneration and other documents as well as administrative requirements for handling disclosures of certificates of medical remuneration and other documents. In the course of disclosing certificates of medical remuneration (health insurance claims), HGST asks the in-network healthcare provider or other medical institution which issued the health insurance claim whether disclosure is appropriate because it is difficult for HGST to determine whether the disclosure of the health insurance claim would hinder the medical care of an individual.
HGST does not charge disclosure fees as a general rule but will charge the actual costs of sending documents if a reply or other response is requested by postal mail.
Please do not hesitate to contact HGST with any other inquiries you may have.
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