Policy for Protection of Private Information
Policy for Protection of Private Information
Policy for Protection of Private Information

The Onward Group (the Group) is aware that, in the course of conducting its business activities, it has a major responsibility to protect the private information of individuals. Accordingly, the Group observes the stipulations of the Private Information Protection Law and, in 2005, issued a policy for strict voluntary guidelines under various legal provisions. The Group is making full efforts to protect private information by making all management and staff aware of the Group’s policy regarding private information.

1. Objectives of the Private Information Protection Policy
（1） To ensure the realization of the protection of private information and continue to offer customers assurance and peace of mind.
（2） To ensure the realization of the protection of private information and continue to provide employees with assurance and peace of mind.
Objectives in Using Private Information
The objectives of the Group in making use of private information are as follows
（1） To keep customers informed regarding the Group’s brands, products, and stores.
（2） To provide information to customers regarding various complementary programs, events, and services.
（3） To conduct surveys
（4） To send products and make payment settlements in the case of catalog sales, etc.
（5） To conduct activities related to research and development related to products, etc., and make requests for surveys regarding product development, improvements in services, and other marketing-related activities.
（6） To make contacts with customers in connection with items (1) to (5) above.
2. Handling of Private Information
In handling private information related to customers and related to employees, the Group will establish supervisory systems for the protection of private information in line with the realities of operations and handle such information appropriately and carefully.
（1） Acquisition of Private Information
When collecting private information, the Group will make clear the objectives of gathering such information and will make use of legal and fair methods to collect such information within the limits of what is necessary for accomplishing the Group’s objectives.
（2） Usage of Private Information
When making use of private information, the Group will use such information within the limitations of what is necessary to accomplish the objectives of gathering the information and with the approval of customers and employees.
（3） Provision and Safekeeping of Private Information
When private information is provided to third parties or assigned to third parties for safekeeping, etc., the Group will select appropriate third parties and take the necessary measures to supervise the activities of these third parties while also ensuring that the information is used within the limitations of what is necessary to accomplish the objectives of collecting the information and what has been approved by customers and employees. Note that when information is provided to third parties or assigned to third parties for safekeeping, etc., the Group will obtained the prior approval of customers and employees.
3. Implementation of the Group’s Safety Policy

To ensure the accuracy and safety of private information, the Group will implement security policies beginning with the enactment of information security policies to prevent improper access to private information as well as the loss, destruction, falsification, or leakage of such information. In addition, if, as a result of internal auditing, it is discovered that there have been instances of security violations and reforms are necessary to meet the requests of customers and employees, the Group will take corrective action without delay.

4. Compliance with Laws and Regulations

To ensure the realization of the protection of private information, the Group will follow the stipulations of the Private Information Protection Law and the guidelines issued by the organizations in which Group companies are members.

5. Continuing Reforms in the Group’s Compliance Program

The Group will continue to make reforms and improvements in its compliance program as the Compliance Committee conducts reviews of the compliance program to ensure that these activities are conducted in the best ways possible.

6. Respect for the Interests of Customers and Employees

The Company will respect the rights of customers, and, when customers and employees request, the Company will disclose its own information, make corrections and deletions, and will respond without delay when customers and/or employees reject the usage and/or provision of such information.

Prepared by the Onward Compliance Committee in February 2005.
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