Japanese Personal Information Protection Act

Article-by-Article Commentary

About This Commentary: This comprehensive article-by-article commentary covers Japan's Personal Information Protection Act with detailed examination of administrative interpretations and legal considerations for each provision.

Publication Method: Progressive release by chapter and section

Author: Prof. SUZUKI Masatomo, LL.M., Ph.D. (Niigata University)

Publication Status:
Available Now Coming Soon Under Development

How to Use: Click on "Administrative Interpretation" links to view detailed English explanations. "Analysis and Consideration" sections will be published as separate academic papers with bibliographic information listed here upon publication.

Chapter 1: General Principles
Overall Structure
Coming Soon
Chapter 2: Purpose and Principle of Respect for Individuals
Section 1: Legal Purpose (Article 1)
1. Administrative Interpretation
2. Analysis and Consideration (To be published as separate paper)
Section 2: Principle of Respect for Individuals (Article 3)
1. Administrative Interpretation
2. Analysis and Consideration (To be published as separate paper)
Coming Soon
Chapter 3: Definitions (Priority Section)
Section 1: General Overview
1. Subjects (Controllers), Target Information, and Acts
— Information-Centric Approach in Japanese Law
2. Processed Information and Scattered Information
— Ambiguous Distinction and Regulation in Japanese Law
3. Public-Private Dualism
Section 2: Target Information (Common Definitions for Private and Public Sectors)
Subsection 1: Personal Information (Article 2, Paragraph 1)
2. Analysis and Consideration (To be published as separate paper)
Subsection 2: Personal Identification Codes (Article 2, Paragraph 2)
2. Analysis and Consideration (To be published as separate paper)
Subsection 3: Sensitive Personal Information (Article 2, Paragraph 3)
2. Analysis and Consideration (To be published as separate paper)
Subsection 4: Private Sector Definitions
— Personal Information Database, Personal Data, Retained Personal Data (Article 16)
2. Analysis and Consideration (To be published as separate paper)
Subsection 5: Public Sector Definitions
— Retained Personal Information (Article 60)
2. Analysis and Consideration (To be published as separate paper)
Subsection 6: Personal Related Information (Article 2, Paragraph 7)
2. Analysis and Consideration (To be published as separate paper)
Subsection 7: Pseudonymized Information (Article 2, Paragraph 5)
2. Analysis and Consideration (To be published as separate paper)
Subsection 8: Administrative Agency Anonymously Processed Information (Article 60, Paragraph 1)
2. Analysis and Consideration (To be published as separate paper)
Subsection 9: Anonymously Processed Information (Article 2, Paragraph 6)
2. Analysis and Consideration (To be published as separate paper)
Subsection 10: Administrative Agency Anonymously Processed Information Files (Article 60, Paragraph 1)
2. Analysis and Consideration (To be published as separate paper)
Subsection 11: Ordinance-Specified Sensitive Personal Information
2. Analysis and Consideration (To be published as separate paper)
Column: Statistical Information (Statistics Act)
Section 3: Subjects
Subsection 1: General Overview
Subsection 2: Personal Information Handling Business Operators, etc.
1. Administrative Interpretation
1. Personal Information Handling Business Operators (Article 16, Paragraph 2; Article 2, Paragraphs 9, 10, 11; Schedule 2)
2. Personal Related Information Handling Business Operators (Article 16, Paragraph 7)
3. Pseudonymized Information Handling Business Operators (Article 16, Paragraph 5)
4. Anonymously Processed Information Handling Business Operators (Article 16, Paragraph 6)
2. Analysis and Consideration (To be published as separate paper)
Subsection 3: Administrative Agencies, etc.
1. Administrative Interpretation
1. Administrative Agencies (Article __)
2. Local Public Bodies
2. Analysis and Consideration (To be published as separate paper)
Subsection 4: Regulatory Transition Corporations
2. Analysis and Consideration (To be published as separate paper)
Subsection 5: Academic Research Institutions, etc. (Article 16, Paragraph 8) and "Academic Research Purposes"
2. Analysis and Consideration (To be published as separate paper)
Section 4: Acts
Subsection 1: General Overview
Subsection 2: Handling
2. Analysis and Consideration (To be published as separate paper)
Processing
Subsection 3: Other Acts
1. Administrative Interpretation
1. Provision
2. Notification to Data Subject
3. Publication
2. Analysis and Consideration (To be published as separate paper)
Subsection 4: Data Subject Involvement
1. Administrative Interpretation
1. Data Subject's Consent
2. Opt-out Procedures
2. Analysis and Consideration (To be published as separate paper)
PDF Available

Upcoming Chapters (Under Development)

About This Commentary

This comprehensive article-by-article commentary represents years of research and analysis of Japan's Personal Information Protection Act. Each "Administrative Interpretation" section provides detailed English explanations of official government guidelines and interpretations.

Structure: Each provision is divided into two parts:

Updates: This commentary is regularly updated to reflect the latest administrative guidelines and legal developments. Last updated: September 2025.