• Policy regarding the protection of personal information
• Disclosure of purpose of use of personal information
• Sharing personal information
• Matters requiring consent

Policy regarding the protection of personal information

The Hewlett-Packard Japan Health Insurance Society promotes the following efforts for appropriately protecting confidential information on its members (hereunder referred to as “personal information E.

• By implementing appropriate security measures, the Society shall endeavor to prevent the leakage or loss of or damage or unauthorized access to personal information obtained on its members.
• The Society shall use personal information obtained from a member only for purposes beneficial to the member, such as the maintenance and promotion of the member’s health. In addition, the Individual Numbers will only be used for specific purposes of use within the range of use established in the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure.
• The Hewlett-Packard Japan Health Insurance Society will not provide the personal information of members to any third party except in cases where the consent of the individuals concerned has been obtained in advance. In addition, personal information which includes the Individual Numbers (the Specific Personal Information hereinafter) will not be provided regardless of whether the consent of the individuals concerned has been obtained except the cases as established in the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure. However, in the cases in Article 27, paragraph (1) of the Act on the Protection of Personal Information (Act No. 57 of May 30, 2003), the personal information of members which is not the Specific Personal Information may be provided to third parties without obtaining the advance consent of the individuals concerned:
• The Society shall endeavor to manage personal information in an appropriate manner by training employees for the protection of personal information and assigning individuals responsible for such management in each section charged with handling personal information.
• Where the Society outsources operations to other parties, it shall review and enhance such operations to improve the protection of personal information. When concluding contracts for the outsourcing of such operations, the Society shall thoroughly investigate the appropriateness of the counterparties to such contracts and shall ensure that the terms and conditions of such contracts include terms concerning the protection of personal information.
  
• When members wish to inquire into, revise, or otherwise access their personal information, the Society shall respond as swiftly as reasonably possible upon contact made by the member to the appropriate representative of the Society.
• In addition to complying with all laws, regulations, and other rules concerning the handling of personal information on its members, the Society shall endeavor to continually review and improve its policies regarding the protection of personal information.

Disclosure of purpose of use of personal information

Disclosure of purpose of use of personal information held by the Hewlett-Packard Japan Health Insurance Society

The Hewlett-Packard Japan Health Insurance Society (hereunder referred to as “Society E prepares a personal-information database based on personal information provided on notices and applications submitted by insured individuals and their family members (hereunder referred to as “members E, personal information contained in the detailed medical statements (hereunder referred to as “detailed statements E sent by medical institutions to the Society indicating the details of medical costs for which payment is demanded, and personal information such as quantitative results of health examinations, using this database for the purposes discussed below.
The Society’s purposes of use of personal information in the broad sense are “the provision of insurance benefits relating to members Eillnesses, injury, or death, excluding employment injury, or childbirth Eas established in the Health Insurance Act, meaning “providing services necessary to the maintenance and promotion of the health of members. E
However, since the business of a Health Insurance Society involves the handling of large volumes of personal information such as detailed statements, examination data, and other medical and other information, and since it is a business requiring high confidence from members, guidelines issued by the Ministry of Health, Labour and Welfare note that it is desirable that the purpose of use of such information be restricted in more precise terms.
For this reason, the Society’s purpose of use of personal information and methods of such use are disclosed below.

• Notices and other documents related to eligibility for coverage are used in Society operations as described below:
  • The Society prepares a master database by entering information obtained chiefly from applications for eligibility submitted when a member applies for coverage and from the details provided in dependent (change) notices (insurance card symbols and numbers, names, dates of birth, gender, addresses, pension numbers, monthly salary, etc.); stores this data on its computers used for operations; and uses this information throughout its health insurance operations.
  • When a dependent (change) notice has been submitted, determination of whether to approve a dependent as eligible for coverage is based on documents such as tax certificates and certificates of enrollment used to determine income and other criteria.
  • Health insurance cards will be issued after an examination of notices of eligibility and dependent (change) notices is complete.
  • When a notice of loss of eligibility has been received, we ask the individual in question to return his or her health insurance card, which we then check and retain for a fixed period of time before disposal.
  • When data stored in the master database needs to be changed or added, data is updated based on submitted change (revision) notices concerning eligibility.
  • The master database is used to link benefits data, data from detailed statements, health examination data, and other information, as well as to check matters such as payment of benefits, to notify individuals of medical costs, and to select eligible individuals and notify members concerning various health-insurance services.
  • Addresses, names, and other contact information in the master database is occasionally used, when necessary, to contact members at their points of contact indicated on notices and other documents, even after they are no longer eligible for coverage under the Society’s health insurance.
  • When an inquiry has been made to the Society from a medical institution or another insurer (including a municipal government or a pension insurance office) concerning the eligibility of a member, after confirming the identity of the inquiring party, the Society will respond by stating whether or not the relevant member is eligible for coverage, based on information such as his or her health insurance card symbol and number, name, date of birth, gender, date of first eligibility, and date of loss of eligibility, as contained in the master database.
  • If it suspects that an individual no longer eligible for coverage has undergone examination or treatment, the Society may check with medical institutions or other insurers concerning information such as his or her health insurance card symbol and number, name, date of birth, gender, date of first eligibility, and date of loss of eligibility as contained in the master database to prevent duplication of benefits with such institutions or insurers.
  • Data from notices of bases for calculation and notices of changes in monthly income is incorporated into the master database and used to collect insurance premiums (including adjusted premiums and premiums for long-term care insurance). Additionally, when such notice has been received, the Society will ask the member’s employer to provide payroll information for the purpose of confirmation.
  • When individuals are eligible for family health examinations, or individuals covered by voluntary continuation of health insurance after departure from the company are eligible for comprehensive medical examinations, their health insurance card symbols and numbers, names, dates of birth, gender, dates of first eligibility, dates of loss of eligibility, and addresses as contained in the master database are provided to the contracted examination facility, JAPAN MEDICAL FOUNDATION (the Occupational Health Society) for use in sending information on applying for such examination and handling reservations.
  • Health insurance card symbols and numbers, names, dates of birth, genders, dates of obtaining eligibility, dates of loss of eligibility, and addresses as contained in the master database are provided to the contracted examination facility, JAPAN MEDICAL FOUNDATION (the Occupational Health Society), and its partner examination facilities for applicants for health examinations, for the purpose of handling examination reservations and sending examination results.
  • For use of WELBOX services, employee numbers, names, and gender are provided to the contracted EWEL Service, Inc. for use in applications for use of the relevant facilities.
  • His/her documents are used for confirmation of qualification whether or not the person is eligible for receiving a subsidy for accommodation, sports club subsidy, or a subsidy for Konami Sports Club via WELBOX.
• Applications for cash and other benefits are used in the following Society operations:
  • Data is entered into the computers used in operational processing and used to check the content of applications and determine appropriate benefits.
  • Data on records of benefits is entered into the computer systems and used to check subsequent applications.
  • Insurance card code number, name, and address data recorded in the Master Database with respect to claimants for childbirth and childcare lump sum payment will be given to Akachantomama Sha Co., Ltd. and such claimants will be sent a book on child rearing.
  • For members requesting payment of childbirth and childcare lump-sum grant for themselves or for family members, the Society shall determine benefits by checking with other insurers concerning information such as health insurance card symbol and number, name, and date of birth from the master database, to prevent duplication of benefits with such insurers.
  • When an inquiry has been made to the Society from another insurer concerning whether a member has requested payment of childbirth and childcare lump-sum grant for herself or for a family member, after confirming the identity of the inquiring party, the Society shall respond by stating whether or not the relevant member has applied for such benefits, and whether or not payment has been made.
    
  • When a member requests payment of benefits for an illness or injury, the Society determines benefits by checking data from the detailed statements and, if necessary, visiting the member.
  • The checking of the content of medical expenses for treatments such as judo therapy and dependent medical expenses will be subcontracted to Gulliver International Co., Ltd. and payment determinations will be made based on the results thereof.
• Data from detailed statements shall be loaded into the Society’s computers used for operations. This information is used throughout its health insurance operations.
  • The Society checks data from detailed statements. In the event of concerns with regard to content, the Society will request re-examination by the Social Insurance Medical Fee Payment Fund.
  • The checking of claim content will be subcontracted to Kabushiki Kaisha Shakai Hoken Shisutemu Kenkyukai.
  • In the process of requesting re-examination, should concerns arise that a member may have undergone an examination after losing his or her eligibility, the Society shall check by communicating to the relevant medical institution the name of the Society and the member’s health insurance card symbol and number, name, date of birth, date of loss of eligibility, date of examination, etc.
  • Similarly, with regard to public coverage and local-government assistance for patients expected to incur high medical costs, the Society shall check by communicating to the relevant medical institution the name of the Society, and the member’s health insurance card symbol and number, name, date of birth, etc.
    
  • Data from detailed statements shall be used in analyses of medical costs to ensure medical costs paid by the Society are appropriate and to select individuals eligible for follow-up guidance and lifestyle- and preventive-care education following examinations.
    
  • Data from detailed statements shall be used in determining and providing guidance to members undergoing examinations at multiple medical institutions in a single month.
  • Data from detailed statements shall be used in determining amounts of benefits for high medical costs and additional benefits (i.e., patient cost-sharing reimbursement, additional benefits for high total medical costs, and medical care additional sum for dependents).
  • Data from detailed statements shall be referenced in determining amounts of benefits paid for illness and injury.
  • Data from detailed statements shall be referenced in determining amounts of benefits paid for judo therapy and secondary dependant medical expenses.
  • Data from detailed statements shall be referenced in determining amounts of benefits paid for burial expenses for members and their family members.
  • When requested to disclose such information, the Society shall output data from the relevant detailed statements. Requests from parties other than the individuals covered by such data shall be accepted only from parties approved in accordance with disclosure request procedures.
  • Data from detailed statements shall be used to determine if any elderly members have been hospitalized for extended periods and to provide public health nursing consultation services.
  • When a member has been treated at a medical institution using his or her health insurance card for injuries sustained due to the actions of a third party, including injuries from traffic accidents, a copy of the relevant member’s detailed statement shall be provided to the casualty insurance company as a certificate of medical costs.
  • The calculation of the overseas medical expenses of persons who receive medical care overseas will be subcontracted to the Research Institute of Employee Benefits.
  • The translation of detailed reports for medical services received overseas shall be entrusted to outside translators for translation into Japanese.
  • In applying for joint operations conducted by the National Federation of Health Insurance Societies (NFHIS) and the Society, under which NFHIS pays a part of high medical expenses incurred, the Society submits to Joint Business Section I of the NFHIS a copy of the detailed statement and an application for payment including some details from the statement.
• Health examination operations are outsourced to the contracted examination facility of JAPAN MEDICAL FOUNDATION (the Occupational Health Society).
  • Members undergoing examinations are notified of numerical results, and such numerical data is obtained from the contracted examination facility and entered into the Society’s computers used in operations, after which it is used to select individuals eligible for follow-up guidance and lifestyle and preventive-care education following examinations.
  • The Society conducts health examinations jointly with employers. In principle, all numerical results of health examinations for insured individuals are communicated to the employers. Such data is retained by both the Society and the employer for use in providing health management services for the insured (employee).
  • Data on results of health examinations is stored in the master database and used for reference when providing health management and health guidance services through comparison with subsequent data.
• Data on the Society’s executive officers and lists of Society board members and business-facility representative
  • Lists of Society board members and directors are used for notifications concerning board meetings and similar functions.
  • Lists of Society business-facility representatives are used for notifications concerning meetings for business-facility representatives, operational committee meetings, and other operational notifications.
• When various printed materials are distributed in connection with the Society’s health insurance services, the packing and distribution of such materials is entrusted to outside vendors.
  • Data on the names and addresses of insured individuals is provided to such vendors for use in sending printed materials.
• Specific Personal Information
  • The Specific Personal Information is personal information which includes the Individual Number (commonly called My Number; including numbers, symbols, and other codes other than a resident code, which correspond to the Individual Number and can be used in place of such Individual Number).
  • A range of use for the Specific Personal Information has been established in the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (the Numbers Act hereinafter), such as information sharing between persons conducting the administrative affairs of a government agency, etc. (example: receiving tax and tax exemption information from a municipality when authorizing dependents for a health insurance society), and the Society will not use the Specific Personal Information beyond specific purposes of use within the range of use established in the Numbers Act.
  • Note that notifications as described in 1 and 2 above may be affixed with the Individual Number and thus be the Specific Personal Information, and if used per the purposes of use and the methods of use described in 1 and 2 fall outside the range of use established in the Numbers Act; accordingly, in such cases measures will be taken such as the masking or removal of the Individual Numbers.
• Creation of anonymously processed information and provision to third parties.

  For purposes including the performance of benchmark analysis with other health insurance societies and the connection of the results to more meaningful policies for all of our members, we use detailed statement data and examination data to create anonymously processed information—which is processed so as to prevent both the identification of specific individuals and the restoration of the personal information used for data creation—and regularly provide the information to IQVIA by using methods for which security has been established.
  

  The items included in the anonymously processed information we create and provide are indicated below.

  Target data: the detailed statement data and examination data of members for April 2015 and later

  Items included in anonymously processed information

  • Gender, detailed medical statement information, health examination history and results, and eligibility information (insured period, withdrawal period, individual/family category, etc.) by age group evrey 5years

  Deleted items (information related to the identification of individuals)

  • Member names, dates of birth, ages, health insurance cards, and insured-individual symbols, numbers, etc.

  Items replaced with other descriptions via a method for which restoration is not possible

  • Member IDs, detailed statement IDs, and the names of medical institutions that issued detailed statements
  

  Provided to:Provided to: IQVIA Solutions Japan K.K.

  Click the image to display an enlarged view in a separate window.

In addition, the Society stores, administers, and disposes of personal information as follows:

• After its input processing is complete, personal information in paper form, such as that shown on various notices, applications, and detailed statements, is stored in a warehouse for the specified number of years, in accordance with the Society’s document administration rules. Except when necessary for confirmation or other purposes, such documents are not removed from their storage locations.
  In addition, personal information in other than paper form is stored and administered appropriately in accordance with the operational administration rules applying to the storage of non-paper media.
• Personal data whose designated storage periods have expired and personal data no longer needed because processing is complete are disposed of as follows: Paper documents are shredded so that they are no longer legible; large volumes of personal data are disposed of by Nihon Purple Co., Ltd. through liquefaction.
  In addition, personal computers and magnetic media are disposed of by first rendering their data unreadable using data-removal software, then disposing of them or returning them to their lessors.

Sharing personal information

According to the Personal Information Protection Law, the provision of personal information to a third party in principle requires the consent of the subject of such information. However, the following cases are not regarded as provision of information to third parties under the law: (1) provision to subcontractors; (2) provision in connection with merger or consolidation; and (3) joint use within a group of companies.
Hewlett-Packard Japan Health Insurance Society conducts health examination activities, mental disease preventions, and mental health educations together with the employer health management division and uses the data jointly.
In addition, the Society uses data from detailed medical statements jointly with the National Federation of Health Insurance Societies (hereunder referred to as “NFHIS E to receive subsidies under which NFHIS pays a part of any high medical expenses incurred by the Society.
For these reasons, pursuant to law, the Society hereby discloses the following information regarding joint use of personal information: (1) the purpose of the joint use of personal information; (2) the items of personal data to be jointly used; (3) the scope of parties using the personal information; (4) the purpose of use of the parties using the information; and (5) the name or title of the individual responsible for administration of personal data.

Joint health examination activities conducted with employers

To ensure that efficient and effective health management services are provided to insured individuals (employees), the Society conducts joint health examination activities with employers.

1.  Health examination activity

• (1)  Jointly used personal data
  Health examination data concerning insured individuals (employees)
• (2)  Scope of parties using health examination data
  The employer health management division
  Hewlett-Packard Japan Health Insurance Society
  
• (3)   Purpose of use of joint users of health examination data
  In accordance with the goals of the Industrial Safety and Health Law, the health management division of the enployer promotes the maintenance of workplace health and safety for its employees and efforts to build a comfortable working environment. Together with the Hewlett-Packard Japan Health Insurance Society, it also seeks to maintain and promote employee health so that they can live healthy lives both within and outside of the workplace.
  Specifically, health examination data is stored in the health management division of the enployer, and health consultation and guidance services are provided by the company’s public health nurses, in accordance with instructions from the company’s industrial physician.
  In accordance with the goals of Article 150 of the Health Insurance Law, the Hewlett-Packard Japan Health Insurance Society provides the employer with a list of employees subject to specific health guidance and records of participation in health guidance and asks the employer to encourage their employees to participate in programs provided by the Society. The Society also seeks to maintain and promote the health of insured individuals, together with the health management division of the employer.
• (4)  Name or title of the individual(s) responsible for administration of health examination data
  Employer: the person in charge of the health management division
  Our Society: the Managing Director

2.  Mental disease prevention activity

• (1)  Jointly used personal data
  Contents of the interview held at Kanda-higashi clinic or its partner medical institution that insured persons (employees) agreed to disclose.
• (2)  Scope of parties using personal data
  Health management division of the employer
  Hewlett-Packard Japan Health Insurance Society
• (3)   Purpose of use of joint users of personal data
  In accordance with the goals of the Industrial Safety and Health Law, the health management division of the enployer promotes the maintenance of workplace health and safety for its employees and efforts to build a comfortable working environment. Together with the Hewlett-Packard Japan Health Insurance Society, it also seeks to maintain and promote employee health so that they can live healthy lives both within and outside of the workplace.
  In accordance with the goals of Article 150 of the Health Insurance Law, the Hewlett-Packard Japan Health Insurance Society seeks to maintain and promote the health of insured individuals, together with the health management division of the employer.
  In concrete terms, the Society conducts the proposal, planning, or reworking for activities.
• (4)  Name or title of the individual(s) responsible for administration of personal data
  Employer: the person in charge of the health management division
  Our Society: the Managing Director

Disclosures concerning the High-Cost Medical Care Grant Program Jointly Implemented by the Hewlett-Packard Japan Health Insurance Society and the National Federation of Health Insurance Societies

Under the Act on the Protection of Personal Information, the consent of the principal is required in principle when his/her personal information is provided to a third party. However, the information’s (1) provision to a trustee, (2) provision in connection with a merger or the like, and (3) joint use by a group are not considered provision to a third party under the law. The Hewlett-Packard Japan Health Insurance Society (the “Society”) and the National Federation of Health Insurance Societies (NFHIS) jointly use medical cost detail data, which allows the Society to receive subsidies for medical care costs through the High-Cost Medical Care Grant Program (the “High-Cost Medical Care Program”) offered by NFHIS for any high-cost medical expenses that the Society incurs.

Accordingly, as required by law, the Society discloses as follows regarding the (1) intention of joint use of personal data, (2) personal data to be jointly used, (3) scope of the parties jointly using personal data, (4) purpose of use of parties jointly using personal data, and (5) the name or appellation of the persons responsible for managing personal data.

• Joint implementation of the High-Cost Medical Care Program with NFHIS

  Health insurance societies and NFHIS implement a program based on Article 2 of the Supplementary Provisions of the Health Insurance Act, whereby NFHIS grants subsidies to cover a portion of any high-cost medical expenses incurred by health insurance societies. In order to apply for this program, the Society submits the following to personnel in charge of high-cost medical care at the Grant Program Group of NFHIS: (1) medical cost details (including pharmaceutical statement; hereinafter referred to as “Rezepts”) in the form of CSV formatted electronic Rezepts or copies of paper Rezepts; and (2) “data of payment of a subsidy with summary of the details” or “application for payment of a subsidy with summary of the details” recording (containing) information such as the name and gender of the patient on the Rezepts, whether he or she is the insured person or a dependent family member, whether the services covered were provided as inpatient or outpatient treatment, the year and month of treatment, and the billed amount on the Rezepts. The receipt of this subsidy will lead to a reduction of the high-cost medical expenses paid by the Society.

• Jointly used personal data

  Items stated in the “data of payment of a subsidy with summary of the details” or “application for payment of a subsidy with summary of the details” in the preceding paragraph and all data contained in Rezepts.

• Scope of parties jointly using Rezept data

  • Society: Personnel in charge of benefits
  • NFHIS: Personnel in charge of high-cost medical care, Grant Program Group
  • Subcontractor: ICT & Healthcare Promotion Department, Japan Productivity Center
    and partner companies

• Purpose of use of parties jointly using Rezept data

  The Society, by applying for the High-Cost Medical Care Program, uses Rezept data to receive subsidies in order to cover a portion of the medical care costs.

  Personnel in charge of high-cost medical care at the Grant Program Group, NFHIS receive applications from all health insurance societies. The personnel use the data to check applications from such societies for any errors and to provide appropriate subsidies. In addition, in cases of Rezepts for particularly high medical care costs of 10 million yen or more per month, information such as the amount and the name of the main disease will be disclosed, upon excluding personal information, for use as material in appealing the trend of increasing medical care costs.

• Name or appellation of the persons responsible for managing Rezept data, address, and name of the corporations’ representatives

  Hewlett-Packard Japan Health Insurance Society

  2-2-1 Ojima, Koto-ku, Tokyo

  Chairman of the Board: Yoshiro Tsuruta

  Data manager: Managing Director

  National Federation of Health Insurance Societies

  1-24-4 Minami-Aoyama, Minato-ku, Tokyo

  President: Shunichi Miyanaga

  Data manager: General Manager of Health Insurance Society
  Support Department