JapanWhat is the data security obligation?
In Japan, businesses handling personal information must implement appropriate security measures to prevent leaks, loss, or damage, as required by the Act on the Protection of Personal Information (APPI).
What the Law Says
The Act on the Protection of Personal Information (APPI) imposes mandatory data security obligations on business operators handling personal information in Japan.
Under the APPI, business operators must implement 'necessary and proper' security control measures to prevent leakage, loss, or damage of personal data. These include organizational, human, physical, and technical safeguards aligned with the size and nature of their operations.
Operators must also supervise employees and contractors who handle personal information, and maintain records of data transfers for at least five years. In case of a data breach involving risk of harm, notification to the Personal Information Protection Commission (PPC) is required without delay — generally within 30 days — and to affected individuals if serious harm is likely.
Failure to comply may result in guidance, orders, or administrative penalties, including fines up to ¥1 million for false reporting or refusal to comply with PPC orders.
Statutory TextA Business Operator shall take necessary and proper measures for the safe management of personal data.
— Act on the Protection of Personal Information, s. 20 — Measures for Safe Management of Personal Data
Statutory TextIn the event of a leak, loss or damage of personal data… the Business Operator shall promptly notify the Commissioner [of the PPC].
— Act on the Protection of Personal Information, s. 24 — Reporting of Leakage, etc. of Personal Data
Statutory TextThe Business Operator shall keep records… for a period of five years from the date of termination of the handling of the personal data.
— Act on the Protection of Personal Information, s. 25 — Record-Keeping
What to Do
Conduct a risk assessment of your personal data handling processes.
Implement organizational, human, physical, and technical security controls per APPI s. 20.
Train staff and sign confidentiality agreements with contractors.
Keep records of data transfers and retention for at least 5 years (APPI s. 25).
Prepare an incident response plan and report breaches to the PPC within 30 days (APPI s. 24).
Sources
Not legal advice. This article is general information based on publicly available sources, written for educational purposes. Laws change and individual situations vary. Consult a licensed attorney in your jurisdiction before acting on anything you read here. Last reviewed: 2026-06-08.