Information Security Policy

Japan Marrow Donor Program (hereafter referred to as "JMDP") recognizes that information security and protecting personal information (hereafter referred to as "personal information") are important responsibilities. It has established this policy to ensure that all employees and related parties are fully aware of it and that JMDP strives to protect information security and personal information.

Ⅰ．Information Security

(Basic policy for information security measures)
1. JMDP shall analyze and evaluate risks based on the characteristics of information handled by JMDP, determine measures to be taken, and promote them in a systematic manner.

(Establishment of priority targets)
2. JMDP shall focus its efforts on countermeasures against threats and accidents, with personal information as a priority target.

(Continuous improvement)
3. JMDP shall continuously take measures for information security, taking into consideration the results of self-inspections and audits of information security measures.

Japan Marrow Donor Program (hereafter referred to as "JMDP") recognizes that information security and protecting personal information (hereafter referred to as "personal information") are important responsibilities. It has established this policy to ensure that all employees and related parties are fully aware of it and that JMDP strives to protect information security and personal information.

Ⅱ. Personal Information Protection

(Compliance with laws and regulations)
1. JMDP complies with the "Act on the Protection of Personal Information" (hereinafter referred to as "the Personal Information Protection Law"), as well as guidelines, guidance, and other norms set forth by the government. In addition, JMDP establishes and complies with policies and standards regarding the handling of personal information within the organization.

(Acquisition of personal information)
2. JMDP acquires and retains personal information to the extent necessary to carry out its business activities as stipulated in Article 4 of the Articles of Incorporation.

(Purpose of use)
3. JMDP shall use personal information appropriately within the scope of the following purposes.

（1）Coordination necessary for the bone marrow/peripheral blood stem cell donation mediation program (hereinafter referred to as "Coordination")

（2）Administrative and operational work related to donors and patients (accounting, medical safety measures, etc.)

（3）Research and preparation of materials to improve transplant outcomes, donor/patient safety, and maintenance/improvement of Coordination.

（4）Joint use with coordinators, coordinating physicians, collection centers, transplant centers, the Japanese Red Cross Society, and other organizations and parties deemed necessary by JMDP in order to carry out Coordination.

（5）Provision to overseas registries, etc. approved by JMDP for international Coordination.

（6）Provision to relevant domestic and overseas organizations for reporting adverse effects on the health of donors/patients, etc.

（7）Provision to domestic and overseas physicians, experts, and others to ask for opinions and advice on how to deal with health hazards to donors and patients.

（8）Provision to specialized companies for the purpose of outsourcing specimen testing and other services.

（9）Provision to the Japanese Society for Hematopoietic and Immuno-Cell Therapy and the Japan Hematopoietic Cell Transplant Data Center for their responsibilities such as disease registration.

（10）Provision to organizations approved by JMDP and approved researchers for the purpose of conducting research to improve transplant outcomes, donor and patient safety, and public awareness activities, in a manner that does not allow the identification of individuals.

（１1）Educational campaigns and publicity campaigns of JMDP.

（１2）Administrative services related to donations.

（１3）Other cases in which it is necessary to use personal information for smoothly implementing the activities listed in Article 4 of the Articles of Incorporation.

(Notification or publication of purposes of use)
4. When acquiring and using personal information, except in exceptional cases as stipulated in Article 18, Paragraph 3 of the Personal Information Protection Law, JMDP shall endeavor to notify or publicly announce the purpose of use to the individual concerned and obtain his/her consent as necessary.

(Joint use)
5. For the purpose of use stipulated in 3. above, JMDP shall jointly use necessary personal information with relevant organizations.
【Matters concerning joint use】
Items of personal data to be jointly used—names, addresses, examination data, etc.
Scope of joint users—domestic and overseas organizations with which JMDP has a partnership or cooperative relationship.
The party responsible for managing applicable personal data: Japan Marrow Donor Program.

(Provision to third parties)
6. Except in exceptional cases as stipulated in Article 27 of the Personal Information Protection Law, JMDP shall not provide personal information to third parties in Japan or overseas without the consent of the individual concerned.

(Disclosure)
7. In the event that JMDP receives a request to disclose personal data in its possession, JMDP shall disclose only such personal data as it deems appropriate in accordance with the Personal Information Protection Law and other applicable laws and regulations of JMDP.

(Correction, etc.)
8. If an individual requests the correction, addition, deletion, erasure, or cessation of provision to third parties of his/her personal data, JMDP shall promptly take measures to comply with the request.

(Safety management)
9. JMDP shall take appropriate measures to prevent leakage, loss, damage, unauthorized access, and falsification of personal information, and to ensure its safe management.

(Education of staff, etc.)
10. JMDP shall provide ongoing training and appropriate supervision to ensure that employees and others who handle personal information comply with the Information Security Policy.

(Outsourcing)
11. When JMDP outsources all or part of the handling of personal information, JMDP shall appropriately supervise outsourcers to ensure that the personal information is securely managed.

(Handling of complaints)
12. JMDP shall promptly respond to complaints regarding the handling of personal information.

(Modification of policy)
13. JMDP reserves the right to modify this policy in accordance with enactment of laws or revision of guidelines and guidance.

(Specific personal information)
14. JMDP shall comply with the "Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (hereinafter referred to as "the Numbers Act")," "Personal Information Protection Law," and guidelines and other norms established by the government regarding personal information including personal numbers (hereinafter referred to as "specific personal information"). In addition, JMDP shall establish and comply with policies and regulations regarding the handling of specific personal information.

(Provision of specific personal information to third parties)
15. JMDP shall not provide specific personal information to third parties, except as stipulated by the Numbers Act.

(Contact for inquiries)

16. For inquiries, complaints, disclosure, etc., regarding this policy, please contact the following:

Hirose 2nd Building 7F, 3-19 Kanda Nishiki-cho, Chiyoda-ku, Tokyo 101-0054, Japan Japan Marrow Donor Program, General Affairs Department
TEL 03-5280-8111