Act on the Protection of Personal Information

Data centers must ensure that personal information is collected, used, and retained only for explicitly specified purposes communicated to data subjects before or at the time of collection.

Data center operators must verify through contracts with customers that data processing activities align with declared purposes and implement technical controls (such as access restrictions and audit logging) to prevent use-case mission creep.

For facilities hosting multiple customers, this requires granular data segregation and purpose-tracking at the individual dataset level, not just facility-wide policies.

The APPI mandates that personal information be kept accurate, complete, and up-to-date according to operational necessity, requiring data centers to implement monitoring systems that detect data corruption, incomplete records, or stale information within their systems.

Data center facilities must establish processes for correcting or supplementing inaccurate data upon customer request and maintain audit trails demonstrating compliance with accuracy obligations.

This extends to metadata management, backup integrity verification, and data validation protocols that run continuously across hosted environments.

Data centers must implement comprehensive technical and organizational safeguards appropriate to the volume and sensitivity of personal information processed, including administrative measures (staff training, security policies), technical controls (encryption, access management, intrusion detection), and physical security (facility access restrictions, CCTV, environmental monitoring).

The APPI does not prescribe specific technologies but requires proportionate measures documented in a Data Protection Impact Assessment (DPIA) demonstrating that risk levels are acceptable.

Data centers must conduct annual reviews and update measures in response to emerging threats or operational changes.

Data centers must cooperate with customers in providing privacy notices to data subjects that specify data handling practices, including facility location, retention periods, and third-party recipients or processors.

For international facilities, APPI requires explicit disclosure when personal information is transferred outside Japan or processed by overseas processors, with documentation of equivalent protection standards.

Data centers must maintain clear records of what information about their processing activities has been disclosed to end-users and by which customer controllers.

Data centers must implement systems enabling customers to fulfill individuals' rights requests for access, correction, deletion, and portability of personal information within legally mandated timeframes (typically 30 days).

Facilities must maintain secure, auditable processes for confirming data subject identity, retrieving requested information from potentially distributed systems, formatting data for portability (structured, commonly-used format), and documenting fulfillment.

Data centers cannot delay or complicate these processes through technical architecture; systems must be designed with subject-rights fulfillment as a primary operational requirement.

APPI restricts transfers of personal information outside Japan unless adequate safeguards exist, requiring data centers to document legal bases for international transfers (customer consent, contractual necessity, legitimate interests with mitigation) and demonstrate equivalent protection standards in destination jurisdictions.

Data centers must implement technical controls preventing unauthorized cross-border data movement, such as geolocation locks, encryption keys retained in Japan, or contractual restrictions on subprocessor locations.

Documentation must include risk assessments comparing privacy protections in destination countries and evidence of customer awareness and consent for international processing.

Data centers must establish incident response procedures including detection mechanisms, immediate containment measures, investigation protocols, and notification obligations to customers within specified timeframes when personal information security is compromised.

APPI requires notification to the PPC for certain incidents and mandates that customers notify affected individuals without undue delay.

Data centers must maintain detailed incident logs including discovery date, impact assessment, remedial actions, and preventive measures, with annual reporting of security incidents to regulatory bodies and customers.

As processors, data centers must execute binding contracts with customers specifying permitted purposes, subprocessor authorization procedures, data security obligations, audit rights, and data deletion/return procedures upon contract termination.

Contracts must explicitly address the data processor's responsibility for staff confidentiality, international transfer conditions, and liability for security breaches.

Data centers cannot unilaterally modify processing terms; customer consent is required for operational changes affecting data handling practices, with mechanisms for customers to terminate relationships if new terms are unacceptable.