Salesforce
Health Association

Personal Information Protection

Privacy Policy

The Salesforce Health Association (hereinafter, the “Health Association”) provides various healthcare services aimed at maintaining and improving health as well as insurance benefits for insured persons and their dependents (hereinafter, “enrollees”). We have established the following policies regarding personal information in order to earn the trust of everyone involved when providing these services, and we will endeavor to appropriately acquire, use, and protect personal information.

Salesforce Health Association Personal Information Protection Policy
(Privacy Policy)
The Salesforce Health Association conducts the following initiatives from a stance of properly protecting the personal information of each enrollee (hereinafter, “personal information”).
  1. The Health Association has put in place the proper measures to protect the personal information collected from enrollees in an effort to prevent any leak, loss, damage, or unauthorized access to the personal information of enrollees.
  2. The Health Association only uses personal information provided by enrollees for the purposes believed to benefit every enrollee, such as maintaining and promoting better health. The Health Association also only uses individual numbers for the designated purposes and range stipulated by the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedures.
  3. The Health Association never discloses personal information about an enrollee to a third party without prior consent. Moreover, the Health Association never discloses personal information which includes individual numbers (hereinafter, “personally identifiable information”) regardless of whether an enrollee gives consent, except when said disclosure is stipulated in the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedures.
    However, in cases where any of the items of Article 27, Paragraph 1 of the “Act on the Protection of Personal Information” (Law No. 57, May 30, 2003) apply to personal information that is not personally identifiable information, we may provide enrollees’ personal information to a third party without obtaining their prior consent.
  4. The Health Association provides education and raises awareness about the protection of personal information in all of its employees and appoints an officer responsible for handling personal information in an effort to properly handle any and all personal information.
  5. The Health Association reviews and enhances any outsourcing operations to ensure an even higher level of personal information protection. When entering into any outsourcing agreement, the Health Association carefully evaluates the qualifications of each outsourcer and makes certain even the terms and conditions of contracts provide the utmost protection of personal information.
  6. The Health Association strives to ensure the personal information of enrollees is as up-to-date, accurate, and protected as possible. Enrollees may make inquiries, corrections or any other such requests regarding their personal information by contacting the Health Association’s service desk. The Health Association will respond as soon as reasonably possible.
  7. The Health Association complies with all laws, regulations and other standards related to the handling of the personal information of enrollees and consistently revises and improves the terms and conditions of this privacy policy.
Contact person in charge
Salesforce Health Association
TEL：03-4222-3000　
E-mail：info@salesforce-kenpo.jp
Reception hours: 9:30～18：00 （Excluding Saturdays, Sundays, national holidays, and year-end and New Year holidays）
Disclosure of personal information held by the Salesforce Health Association and the purpose of use
The Salesforce Health Association (hereinafter, the “Health Association”) constructs a personal information database based on (1) personal information listed in various notifications, applications, etc., submitted by the insured person and their family members (hereinafter, “enrollees”), (2) personal information listed in the statement of medical expenses (hereinafter, “insurance claim statement”) billed to the Health Association by the medical institution when the enrollee undergoes treatment at a medical institution, etc., and (3) personal information such as the numerical values of health checkup results when the enrollee receives a health checkup, and then uses the database information for health insurance businesses.
The Health Association uses personal information for the purpose of either providing insurance benefits to enrollees for illnesses, injuries, or deaths not caused by occupational accidents as well as childbirth, or executing operations necessary for maintaining and promoting better enrollee health as provided for in the Health Insurance Act.
As a health association handling a large volume of medical data from insurance claim statements to medical examination results, as well as other personal information, the Health Association’s services require a great deal of trust from enrollees. Therefore, the Ministry of Health, Labour and Welfare has published more detailed guidelines advising clearly defined purposes to limit the use of personal information.
The Health Association shall, as a general rule, handle the personal information collected in Attachment 1 in accordance with the usage purposes outlined in Attachment 2. The purpose and method for using personal information is disclosed below.
Furthermore, the Health Association never uses personal information in its possession for any other purpose than providing healthcare services.
  1. Applicable Notification and Application Forms
    1. The Health Association has configured a master database (hereinafter, “master data”) including an enrollee ledger and stores data on computers for operational processes to use throughout the entire health association for input and processing of health insurance card numbers, names, dates of birth, genders, addresses, monthly remuneration and other items included in Notifications of Qualification as an Insured Person or Notifications of Change of Dependents when individuals enroll in the health association.
    2. The Health Association issues health insurance cards after verifying Notifications of Qualification as an Insured Person and Notifications of Change of Dependents.
    3. When a Notification of Change of Dependents is submitted, certification is carried out based on income-certifying documents such as taxation/non-taxation certificates, copies of student ID cards, etc.
    4. The Health Association requires insured persons to return health insurance cards when submitting a notification of forfeiture of eligibility, which are verified and stored for a fixed period of time before disposal.
    5. The Health Association updates the data registered as master data according to applicable change (correction) notifications to update or add information to the master data.
    6. The Health Association correlates data on benefits, insurance claim statements, health examination and other relevant data using the master data to verify benefit payments and other processes, to identify persons related to notifications on medical care costs and various other healthcare services, and to contact enrollees.
    7. The Health Association may contact individuals using the address, name or any other contact information included on notifications or in the master data as necessary even after said individual loses eligibility as an insured person of the health association.
    8. The Health Association answers inquiries about qualification or forfeiture of eligibility and other such health insurance-related healthcare questions from healthcare providers, other insurers (including municipalities and pension offices), using personal information in the master data such as health insurance card numbers, names, dates of birth, genders, dates of qualification, or dates of forfeiture of qualification, after verifying the identity of the person making the inquiry.
    9. The Health Association may ask other insured persons or third parties about health insurance card numbers, names, dates of birth, genders, dates of certification or loss of qualification or other information in the master data to make adjustments of duplicate benefits of other insured persons or healthcare providers if any discrepancies arise, such as examinations after an individual loses eligibility as an insured person.
    10. The Health Association incorporates data from notifications on the calculation basis and monthly changes into the master data to charge insurance premiums, including adjusted insurance premiums and long-term care insurance premiums. In addition, the Health Association requests employers submit salary and bonus ledgers and other documentation for review when submitting a notification.
    11. Some of the work of creating and inputting the master data, issuance of health insurance cards, and preparation of premium payment notices, etc., will be outsourced to a contractor.
    12. The Health Association provides health insurance card numbers, names, dates of birth, genders, and addresses included in the master data about individuals applying for a physical examination to contract healthcare providers to use when sending results from the examination.
  2. Cash Payments and Other Benefit Application Materials
    1. The Health Association enters data on computers for business processing and reviews application details to make proper payment decisions.
    2. Payment records are saved as data entries and used for subsequent application checks.
    3. The Health Association may ask a third-party insured person about health insurance card numbers, names, dates of birth and other information in the master data about individuals requesting childbirth and childcare lump-sum allowances or dependents’ childbirth and childcare lump-sum allowances when necessary for adjusting duplicate benefits of other insured person to make payment decisions.
    4. The Health Association responds to inquiries about whether a request was made for childbirth and childcare lump-sum allowances or dependents’ childbirth and childcare lump-sum allowances from other insured persons by providing information about applications and benefits after verifying the identity of the person making the inquiry.
    5. The Health Association reviews data on insurance claim statements of individuals requesting injury or illness allowance and asks the physician in charge for verification or evaluation, the status of medical treatments, and any other applicable information as necessary to make payment decisions.
    6. We will outsource to outside vendors the processing for entry of benefit-related application documents in the Health Association’s computers for administrative processing, the checking of application contents, payment processing, etc.
  3. Statement of Medical Expenses (Insurance Claim Statement)
    1. The Health Association stores images and data of health insurance claim statements by the Health Insurance Claims Review & Reimbursement Services on its computers for business processing to use in healthcare businesses.
    2. The Health Association reviews insurance claim statement data and requests a secondary evaluation by the Health Insurance Claims Review & Reimbursement Services for any questions arising about a claim.
    3. As part of this request for a secondary evaluation, the Health Association shares the name of the health association, the health insurance card number, name, date of birth, date of loss of qualification, the date on which medical care was provided and other relevant information with the healthcare provider for confirmation if a question arises about an exam after the individual loses their qualification as an insured person.
    4. As part of a review of whether there are public expenditures of patients expected to pay high-cost medical expenses or medical cost subsidies from a municipality, the Health Association shares the name of the health association, the health insurance card number, name, date of birth, and other relevant information with the healthcare provider for confirmation.
    5. The Health Association uses insurance claim statement data to analyze medical costs and ensure no billing errors of the health association as well as to provide post-health guidance after health checkups, and to identify candidates for education to prevent lifestyle-related diseases.
    6. The Health Association uses insurance claim statement data to identify and provide guidance to enrollees who have undergone examinations at several healthcare providers in the same month.
    7. The Health Association uses insurance claim statement data to make decisions on payments of high-cost medical expenses and benefits, such as co-payment reductions, additional aggregated high-cost medical expenses, and additional family medical expenses.
    8. The Health Association refers to insurance claim statement data to make payment decisions about injury and illness allowances.
    9. The Health Association refers to insurance claim statement data to make payment decisions about therapies and other medical treatments performed by judo therapists as well as medical costs for family dependents.
    10. The Health Association refers to insurance claim statement data to make payment decisions about funeral expenses of an insured person or family.
    11. The Health Association responds to requests for disclosure of insurance claim statements by providing relevant data for said insurance claim statements. Moreover, the Health Association only discloses information to approved parties in accordance with disclosure rules pertaining to disclosure requests.
    12. The Health Association provides insurance claim statement data to contractors to notify enrollees of medical care costs.
    13. The Health Association submits copies of insurance claim statements of relevant patients for any medical care provided due to traffic accidents or actions of a third party to non-life insurance companies and administrative contractors handling reimbursement of medical costs.
    14. The Health Association outsources Japanese translations of statements of medical care costs and other documentation received from healthcare providers overseas to an external translation contractor.
    15. The Health Association sends a copy of insurance claim statements and applications including some of the details in the course of applications to joint projects to pay high-cost medical expenses run by the National Federation of Health Insurance Societies (Kenporen) to receive subsidy grants.
    16. Insurance claim statement data is stored in the Health Association computers, and the Health Association engages a contractor to check the details of the health insurance claims, perform re-examination procedures, and process payments for high-cost medical care and other expenses.
  4. Health Checkups
    1. The Health Association outsources health checkups to medical contractors.
    2. The Health Association receives the numerical result data from the medical contractor and notifies the patient of said results. The results data is also used to provide guidance after the checkup and identify candidates for education to prevent lifestyle-related diseases.
    3. The Health Association provides health checkups in cooperation with employers. Accordingly, the Health Association contacts every employer about the numerical results of health checkups of insured persons (employees) as a general rule, and Health Association and the employer both store a copy to help in the health management of insured persons.
    4. The Health Association saves result data from health checkups as master data to compare with future data for reference in the provision of health management services and health guidance.
  5. Implementation of Other Healthcare Services
    1. The Health Association provides health insurance card numbers, names, genders, and addresses included in the master data about users of the Cafeteria Plan to contractors to use for various purchasing applications.
    2. The Health Association uses health insurance card numbers, names and addresses in the master data when providing various healthcare services.
    3. Payment of subsidies, etc. is outsourced to a vendor.
  6. Personnel Data on Officers and Employees, List of Society Committee Members, List of Health Insurance Representatives at Workplaces
    1. The Health Association carefully stores all materials about the appointment and hiring of Salesforce officers and employees after use.
    2. The Health Association carefully stores all materials about the remuneration of Salesforce officers and employees to use for tax withholdings and other such processes.
    3. The Health Association uses the List of Society Committee Members and List of Directors when contacting committee members and directors regarding the holding of Society Meetings, Board of Directors Meetings, etc.
    4. The Health Association uses the List of Health Insurance Representatives at Workplaces at the Health Management Promotion Committee and in other business-related liaison work.
  7. Personally Identifiable Information
    “Personally identifiable information” refers to personal information, including individual numbers (My Numbers) or other numbers, codes and symbols used as an alternative to individual numbers, excluding certificate of residence codes.
    The Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (hereinafter, “Act on the Use of Numbers”) defines the usage scope of personally identifiable information, such as the sharing of information between parties involved in administrative processes of government bodies. For example, local municipalities provide information on taxation and exemption of local taxes to health insurance societies for the certification of dependents. Personally identifiable information cannot be used for any purpose other than the specific purposes within the scope of use stipulated by the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures.
    In addition, any use outside the scope of use stipulated in the Act on the Use of Numbers must mask, delete or take other measures to redact individual numbers from personally identifiable information.
  8. Storage Management, Disposal and Deletion of Personal Information
    1. The Health Association’s document management regulations define rules for warehouse storage of any personal information included in various notifications, applications, insurance claim statements, and other paper documents for a prescribed number of years after data entry and restrict anyone from taking said documents out of storage unless necessary for verification or other such processes.
    2. The Health Association also properly stores personal information in non-paper mediums according to operation management rules related to the storage on non-paper mediums.
    3. The Health Association shreds paper documents containing personal data which has passed the prescribed storage period or is no longer necessary after processing into small illegible pieces and outsources disposal of a large quantity of personal data to contract processors which dissolve said documents into pulp.
    4. The Health Association disposes or returns computers and other magnetic storage media by first rendering data unreadable using a data erasing software.
→Attachment 1: Example of personal information held by the Health Association
→Attachment 2: Main usage purposes of personal information foreseen in standard Health Association operations
Disclosure of Personal Information to Third Parties
The Health Association is deemed to have been granted full implied consent for the use of personal information (personal data) when no explicit objection or reservation is raised by the insured person or other concerned parties in its position under Notification No. 0414-(18), “Guidance on Proper Handling of Personal Information at Health Insurance Societies,” issued on April 14, 2017 by the Director of the Health Insurance Bureau of the Ministry of Health, Labour and Welfare for purposes beneficial to insured persons and other concerned parties or in cases where changes to current methods of notification on medical care costs or other such information impose an unreasonable burden on the health association while obtaining explicit consent would also not necessarily be reasonable from the point of view of the insured person, which applies to the provision below.
  1. Disclosure of Personal Information to Third Parties (Scope of Full Consent)
    [Usage Purposes]
    1. To provide notifications on health care costs for a single household
    2. In connection with the use of the My Number insurance card, notification of eligibility information to subscribers (the last four included digits of the personal number) will be sent to insured persons collectively on a household basis.
  2. Items, Procedures and Methods for Disclosure of Personal Information (Personal Data) to Third Parties
    Usage
    Purposes    		 Item of Personal Information for Disclosure to Third Parties Procedure and Method of Disclosure
    1 Names of patients, dates of treatments, payment period, treatment classifications or types of benefits, days, total medical care costs, amount of health insurance coverage, out-of-pocket costs, names of healthcare providers rendering treatments, amount of statutory benefits, amount of additional benefits, and payment dates Disclosed as statements of medical care costs every month on the Health Association website
    2 Symbol, number, branch number, name, furigana
    Percentage of burden, date of eligibility
    Last 4 digits of personal number (My number)    		 Delivery by mail
  3. Handling of Anonymized Data
    “Anonymized data” refers to information related to individuals collected by anonymizing data to remove any personally identified information and ensure the personally identifiable information cannot be recovered to identify an individual.
    The Health Association continuously creates anonymized data for healthcare services, epidemiological surveys, and other such operations in order to provide said data through electronic means of communication to contractors which analyze insurance claim statements. The anonymized data created for provision includes genders, dates of birth, health insurance eligibility, such as enrollment periods, withdrawal periods, and the classifications of the insured persons and family, histories of treatments in statements of medical expenses, and the histories of general health checkups as informational items. This anonymized data never includes any personally identifiable information.
  4. Procedures to Cease Disclosures to Third Parties
    1. Insured persons and other individuals may request that the Health Association obtain explicit consent in advance for any usage purposes which the individual does not feel comfortable granting implicit consent.
    2. If the insured person or other individuals do not express the above intention to cease disclosure, the Health Association deems that it has received full consent for the usage purposes it has announced.
    3. The insured person and other individuals may decide to grant full consent or indicated reservations about disclosing an item at any time.
    Please contact the Health Association using the contact information below if you would like to cease disclosure of any items.
    Contact person in charge
    Salesforce Health Association
    TEL：03-4222-3000　
    E-mail：info@salesforce-kenpo.jp
    Reception hours: 9:30～18：00 （Excluding Saturdays, Sundays, national holidays, and year-end and New Year holidays）
Joint Use of Personal Information: (1) Subsidy Projects Related to Payment of High-cost Medical Expenses
The Health Association uses personal information (personal data) it has collected in the joint projects outlined below.
In addition, Article 27, Paragraph 5, Item 3 of the Act on the Protection of Personal Information stipulates an entity or business operator receiving such personal information (personal data) shall not be deemed a third party and may disclose such personal information (personal data) without the prior consent of the individual in cases in which (1) personal data used jointly, (2) the items of the personal data used jointly, (3) the scope of the joint users, (4) the purpose for which the personal data is used by them, and (5) the name, title, address and corporate representative of the person responsible for the management of personal data is, in advance, notified to the person or put in a readily accessible condition for the person.
  1. Items for Joint Use of Personal Information (Personal Data)
    (1) For statements of medical expenses (including statements of expenses for drug dispensation. Hereinafter, “insurance claim statements”) electronic insurance claim statement data in CSV format or a copy of the paper insurance claim statements, (2) data or written documents for summary statements of subsidy applications recording items such as patient names, genders, insured persons or family dependents, in-patient or out-patient care, dates of treatments, and the amounts of said health insurance claims, in addition to all other items of data included in health insurance claims
  2. Persons or Entities Jointly Using Personal Information
    • Kenporen, subsidy project groups, employees in charge of high-cost medical expenses
    • Contractors of Kenporen (ICT and healthcare promotion divisions and partner companies of the Japan Productivity Center)
  3. Joint Usage Purposes
    Subsidy projects related to payment of high-cost medical expenses
  4. Officer Responsible for Personal Information Management
    • Salesforce Health Association
      1-1-3 Marunouchi, Chiyoda-ku, Tokyo
      Chairman of Board of Director Masanori Suzuki
      Personal Information Management Officer　Executive Director
    • National Federation of Health Insurance Societies
      1-24-4 Minami-Aoyama, Minato-ku, Tokyo
      Chairman Shunichi Miyanaga
      Personal Information Management Officer　Society Support Division　Division Manager
  5. Inquiries
    Contact person in charge
    Salesforce Health Association
    TEL：03-4222-3000　
    E-mail：info@salesforce-kenpo.jp
    Reception hours: 9:30～18：00 （Excluding Saturdays, Sundays, national holidays, and year-end and New Year holidays）
Joint Use of Personal Information (2) Personal Information Used Jointly with Employers
The Health Association uses personal information (personal data) it has collected in the joint projects outlined below.
In addition, Article 27, Paragraph 5, Item 3 of the Act on the Protection of Personal Information stipulates an entity or business operator receiving such personal information (personal data) shall not be deemed a third party and may disclose such personal information (personal data) without the prior consent of the individual in cases in which (1) personal data used jointly, (2) the items of the personal data used jointly, (3) the scope of the joint users, (4) the purpose for which the personal data is used by them, and (5) the name, title, address and corporate representative of the person responsible for the management of personal data is, in advance, notified to the person or put in a readily accessible condition for the person.
  1. Items for Joint Use of Personal Information (Personal Data)
    1. Personal information about individuals including necessary information about dependents such as names, genders, dates of birth, employee numbers, affiliations, positions, addresses, telephone numbers, standard monthly remuneration, standard amount of bonuses, business email addresses, and certifications as a dependents
    2. Information about regular health check-ups, comprehensive physical examinations, and other general health examinations provided by the Health Association including codes, numbers, names, dates of birth, genders, age, addresses, telephone numbers, and email addresses of patients as well as the names of employers, employee codes, dates of heath examinations, dates of reservations for health examinations, names of healthcare providers, items included in the health examinations, numerical results of healthcare examinations, diagnoses, questions asked by physicians, and details of any health guidance
  2. Persons or Entities Jointly Using Personal Information
    • Health Association employees
    • HR managers of employer
    • Medical examiners of employer
    • Industrial physicians
    • Contractors
  3. Joint Usage Purposes
    1. Smooth and precise execution of the Health Association’s operations, such as certifying or revoking eligibility, benefits payments, and healthcare services stipulated for health insurance societies by the Health Insurance Act
    2. Health Association and employer activities for health promotion and prevention of onset and progression of illnesses through aftercare, health guidance, consultations and other measures based on health examination results of insured persons as well as
      evaluations and analyses after taking measures to enhance the effectiveness of projects conducted with employers
  4. Officer Responsible for Personal Information Management
    • Salesforce Health Association
      1-1-3 Marunouchi, Chiyoda-ku, Tokyo
      Chairman of Board of Director Masanori Suzuki
      Personal Information Management Officer　Executive Director
    • Employers and General HR managers
  5. Inquiries and Feedback
    Contact person in charge
    Salesforce Health Association
    TEL：03-4222-3000　
    E-mail：info@salesforce-kenpo.jp
    Reception hours: 9:30～18：00 （Excluding Saturdays, Sundays, national holidays, and year-end and New Year holidays）
Procedures for Disclosure or Correction of Personal Data or Termination of Use
Anyone who would like to request disclosure or correction or stop use of personal data collected by the Health Association may acquire, fill out, and submit the designated application form in accordance with the handling requirements related to the disclosure or correction of personal data or termination of use.
Specific Procedures
  1. Acquire a Request for Disclosure of Personal Information Collected by Health Association to file a request for disclosure of personal information or acquire a Notification of Correction/Termination of Use of Personal Information Collected by the Health Association to file a request to correct or terminate the use of personal information.
  2. Fill in the necessary items.
  3. Prepare the necessary documents to attach. Please ask the Health Association about the necessary document attachments.
  4. Submit the application form and other materials to the Health Association.

The Health Association considers the convenience of everyone filing requests or notifications to make application processes as simple as possible for individuals. The Health Association will respond to any requests or notifications in writing. As a general rule, the Health Association will respond to a request for disclosure by disclosing the information regardless of the reason. However, the Health Association may refuse to disclose information in part or in whole if the disclosure may harm the assets or other interest of a third party, if it may significantly inhibit the proper execution of the Health Association’s operations, or if the Health Association does not have the personal data requested for disclosure. In this case, the Health Association will immediately notify the individual of the reason in writing.

Requests for Disclosure of Statements of Medical Expenses (Insurance Claim Statements)
The Health Association discloses statement of medical expenses (health insurance claims) in accordance with rules on disclosure of certificates of medical remuneration and other documents as well as administrative requirements for handling disclosures of certificates of medical remuneration and other documents. In the course of disclosing statements of medical expenses (insurance claim statements), the Health Association asks the society physician or other medical institution which issued the health insurance claim whether disclosure is appropriate because it is difficult for the Health Association to determine whether the disclosure of the health insurance claim would hinder the medical care of an individual.
The Health Association does not charge disclosure fees as a general rule, but will charge the actual costs of sending documents if a reply or other response is requested by postal mail.
Please do not hesitate to contact the Health Association with any other inquiries you may have.
Return to Top Page
PAGE TOP