Policy Briefing — Japan Updates APPI Foreign Transfer Guidance

Executive briefing: The Personal Information Protection Commission (PPC) revised its Guidelines on the Act on the Protection of Personal Information (Provision to a Third Party in a Foreign Country) on 17 April 2024. The update clarifies how controllers must evaluate foreign jurisdictions, contract with overseas processors, and disclose transfer details to data subjects when exporting personal data from Japan.

Key obligations

• Adequacy assessments. Before transferring data to non-whitelisted countries, controllers must assess local privacy laws, enforcement systems, and risk mitigations, documenting the evaluation.
• Contractual safeguards. Updated Appendix 2 provides standard contractual clauses covering security measures, onward transfers, and breach notification duties.
• Continuous monitoring. Controllers must review transfer assessments periodically and whenever foreign legal frameworks change materially.
• Data subject disclosures. Privacy notices must explain foreign jurisdictions involved, safeguarding measures, and how individuals can obtain further information.
• Record keeping. Organisations must maintain detailed logs of assessments, contracts, and responses to data subject requests.

Program actions

• Update transfer inventories. Catalogue overseas processors, cloud regions, and support centres to prioritise reassessments.
• Refresh contracts. Align data processing agreements with PPC standard clauses, including audit rights and incident notification timelines.
• Enhance transparency. Update privacy notices, FAQs, and customer support scripts to explain foreign transfers and safeguards.
• Monitoring cadence. Establish review triggers for geopolitical or legal changes affecting adequacy conclusions.

Sources

• PPC — Update to APPI foreign transfer guidelines
• Guidelines on the Act on the Protection of Personal Information — Provision to a Third Party in a Foreign Country

Zeph Tech helps Japanese and multinational teams refresh APPI cross-border assessments, contractual safeguards, and transparency artefacts.

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