Cinarra Systems Japan K.K. (headquartered in Minato-ku, Tokyo; Masato Hosoya, President; hereinafter “Shinara”) is a member of the LBMA Japan (headquartered in Chiyoda-ku, Tokyo; Kuniyuki Kawashima, President), a business coalition that promotes marketing and service measures that utilize location information. The LBMA Japan (Location: Chiyoda-ku, Tokyo; Representative Director: Kuniyuki Kawashima), an alliance of companies working to promote marketing and service measures that utilize location information, has established the name “device location data” for location information and other data, and formulated guidelines for its use in developing location information-related businesses.
Device location data is acquired from authorized user terminals for applications and various web services. The acquired data has been utilized by national and local governments, research institutes, and private companies for the purpose of providing information to make life more convenient, distributing special coupons and advertisements, creating statistical data for market research and urban planning, infrastructure development, and disaster countermeasures. Recently, it has also been used as a human flow indicator to prevent the spread of the new coronavirus (COVID-19).
Device location data does not fall under the category of “personal information” as defined by the Personal Information Protection Law, as long as it cannot be used to identify a specific individual by itself and cannot be easily cross-checked with other information to identify a specific individual. On the other hand, depending on the method of accumulation and utilization, device location data has the property of increasing the possibility of visualizing the course of action and the history of stay, and of identifying a specific individual. Until now, businesses that utilize device location data have been using it in accordance with their own rules based on laws and regulations. However, against the backdrop of recent social influences on the use of data, we believe that it is essential to establish industry-wide standards in order to promote sound and sustainable use of data. This guideline will be used by member companies, law enforcement agencies, and the general public. These guidelines were prepared after repeated discussions with member companies, legal professionals, lawyers, ethicists, etc., and after consultation with the Secretariat of the Personal Information Protection Committee and other relevant organizations.
The LBMA Japan will strive to ensure that member companies operate in accordance with these guidelines, and will also establish a system to audit whether the guidelines are being used in accordance with the guidelines.
In addition to these guidelines, Cinarra will promote the creation of operational rules and in-house training for the use of secure data, taking into account the nature of the data handled by the company. In addition, Cinarra will contribute to the update of these guidelines by proactively sharing its own knowledge in order to promote the sound and sustainable use of data.