As a company that is entrusted with the management of valuable assets by the clients, Nikko Asset Management Co., Ltd. (hereinafter referred to as the "Company") believes that it is the Company's mission to handle personal information carefully. In keeping with this mission, the Company hereby announces the Basic Policy for the protection of personal information (hereinafter referred to as the "Basic Policy".)
2. Compliance with Relevant Laws and Regulations
It is the Company's deep conviction that the protection of personal information and the maintenance of confidentiality are its social responsibility. Recognizing this responsibility, the Company pledges that it will handle personal information in an appropriate manner in compliance with the laws concerning the protection of personal information and other relevant laws and regulations as well as in conformity with this Basic Policy.
3. Objectives of the Use of Personal Information
The Company will handle personal information only to the extent necessary for achieving the objectives of use in the following areas of business operations and will not use such information beyond the scope of these objectives. Moreover, the Company will not change the objectives of the use of personal information beyond the scope recognized as rational.
Areas of Business Operations
(1) Investment trust-related investment management operations and other incidental operations.
(2) Investment management operations based on discretionary investment management contract and other incidental operations.
(3) Investment advisory/agency operations and other incidental operations.
(4) Secondary financial instruments businesses and other incidental operations.
(5) Other operations the Company is permitted to perform as well as other incidental operations (including those operations that the Company will be permitted to perform in the future.）
Objectives of Use
(1) To solicit and sell the securities issued or the products provided by the Company, or publicize the securities, products and services issued or provided by the Company.
(2) To solicit, distribute, or introduce the services of the financial products offered by the Company, its affiliates, or business partners; or to introduce the Company's affiliates.
(3) To accept the application for securities, products provided by the Company, or services including the opening of an account for transaction.
(4) To confirm the identity of a client or his or her proxy.
(5) To report the results of transactions, balance and other details to the client.
(6) To process the documents concerning the transactions with the clients.
(7) To conduct the research and development of products provided by the Company and services through market research, data analyses and questionnaire surveys.
(8) To carry out the appropriate processing of personal information in part or in whole the Company is entrusted with by other operators.
(9) To process the documents concerning an investment advisory contract or a discretionary investment management contract concluded with a client.
(10) To provided investment advisory service.
(11) To report the results of investment and the balance of assets under contract.
(12) To perform transactions with the client appropriately and smoothly.
(13) To make necessary contact with the client and respond to his or her needs appropriately and smoothly.
(14) To respond to the enquiry from the client about the handling of personal information.
(15) To implement the Company's business management and internal control.
4. Limitations on the objectives of use where information is obtained through questionnaires, etc.
The Company will make every effort to limit the objectives of use depending on situation of acquiring personal information. For example, when answering various questionnaires, etc., the objectives of use will be clear to the person concerned by stipulating specifically that the information will be used for the sole purpose of gathering information for the questionnaire, etc.
5. Joint use of personal data
The Company may use personal data jointly as follows:
(1)Items of personal data used jointly:
- Items on transaction information including names, addresses, dates of birth, occupations.
(2) Scope of the parties that will jointly use personal data
- The Company
- Sumitomo Mitsui Trust Holdings, Inc. and the consolidated subsidiaries and equity method affiliates listed in that company’s securities reports, as well as the consolidated subsidiaries and equity method affiliates listed in the disclosure material of Sumitomo Mitsui Trust Bank, Limited. (in cases where the joint use of personal data is restricted by the Financial Instruments and Exchange Act or other related laws and regulations, the Company will ensure that personal data is handled in accordance with such laws).
(3) Objectives of the use of personal data
To recognize and manage various risks required for management of the Sumitomo Mitsui Trust Group.
(4) The name of the entity responsible for the management of the jointly used personal data:
Sumitomo Mitsui Trust Holdings, Inc.
6. Sensitive Information
The Company will not obtain, use nor provide to a third party any information concerning political opinions, credos (meaning religion, ideology and beliefs), participation in the labor union, race and ethnicity, family origin and legal domicile, health and medical treatment, sexual orientation and criminal record (hereinafter referred to as "sensitive information") except in the following cases. If the Company obtains, uses or provides to a third party sensitive information for any of the reasons cited below, it will handle it with special care so that such information will not be obtained, used nor provided to a third party for the reasons not cited below.
(1) Where sensitive information is required by laws and regulations.
(2) Where sensitive information is required to protect human lives, physical safety and property.
(3) Where sensitive information is specifically required to improve public health and nurture the healthy growth of the children.
(4) Where the Company is required to cooperate with a government agency, a regional public organization or an entity entrusted with by such agency or organization in the conduct of affairs stipulated by laws and regulations.
(5) Where sensitive information concerning those employees who belong to, or participate in a political or religious organization or labor union is obtained, used or provided to a third party to the extent necessary for processing the documents for the purpose of withholding taxes.
(6) Where sensitive information is obtained, used or provided to a third party to the extent necessary for the transfer of rights and obligations in inheritance procedures.
(7) Where sensitive information is obtained, used or provided to a third party with the consent of the person concerned to the extent necessary for ensuring the appropriate operations of financial instruments businesses and other business activities in the financial field.
(8) Where sensitive biological identification information is used to confirm the identity of the person concerned with his or her consent.
7. Rightful Obtainment of Personal Information
(1) The Company will not obtain personal information by using a false pretext or illegal means.
(2) The Company will not infringe on the interest of the client when it obtains personal information from a third party. Moreover, the Company will not obtain personal information from a third party if it finds that the information in question has been leaked by an entity that is engaged in illegal collection of such information.
(3) The following sources provided below are examples of where the Company may obtain personal information.
- Where the customer directly provides information to the Company by filling out various questionnaires, etc. (this includes cases where the person concerned inputs data into a screen via a website, etc.)
- Where the customer directly provides information by filling out or submitting forms, etc., for the opening of trading accounts, etc., or for a new application form for the Company’s products or services (this includes cases where the person concerned inputs data into a screen via a website, etc.)
- Where the Company obtains personal information by receiving audio- and video- tapes and e-mail.
- Where the Company obtains personal information carried in official gazettes, newspapers, magazines and on the Internet.
(4) The Company may not be able to provide its services in part or in whole if a client has declined to provide personal information requested by the Company.
8. Notice, Public Announcement and Disclosure of the Objectives of Use When Personal Information is Obtained
The Company will announce the objectives of use of personal information on its home page on the Internet.
When the Company obtains personal information, it will promptly notify the person concerned or announce the objectives of use except the case where the objectives of use of such information have been announced in advance.
When the Company obtains personal information directly from the documents provided by the person concerned, it will disclose, as a rule, the objectives of use in advance.
9. Ensuring the Accuracy of Personal Data
The Company will endeavor to keep personal data accurate and up-to-data to the extent necessary for achieving the objectives of use.
The Company will specify the period in which personal data are kept in custody in accordance with the objectives of use and delete such data after the elapse of the specified period except the case where the safekeeping period is specified by laws and regulations.
10. Measures Taken for the Safekeeping of Personal Data
The Company will take appropriate and necessary measures for the safekeeping of personal data in order to prevent leaks and losses of, and damage to such data by establishing the Basic Policy for safekeeping and the regulations of handling personal data as well as setting up a system under which safekeeping measures are implemented.
The appropriate and necessary measures will include the following measures which will be taken when personal data is obtained, used and kept in custody:
- Safekeeping measures on a company-wide basis: The Company will clearly define the responsibility and authority of employees concerning safekeeping measures taken for personal data, establish and implement regulations for safekeeping as well as inspect and audit the condition in which these measures are carried out.
- Safekeeping measures in a human aspect: The Company will conclude the confidentiality agreement on personal data with employees, provide them with education and training as well as carry out appropriate and necessary supervision of employees so that personal data are kept safely in custody.
- Safekeeping measures implemented technically: The Company will control and monitor the access to the information system in which personal data are stored and take other technical measures for the safekeeping of personal data.
11. Disclosure of Personal Data to a Third Party
The Company will not disclose personal data to a third party except in cases that fall under any of the following situations:
(1) Where personal data is disclosed with the consent of the person concerned.
(2) Where the disclosure of personal data is required by the law.
(3) Where personal data is disclosed in response to an inquiry or investigation by the tax authorities, police, court of law or other external agency.
(4) Where the disclosure of personal data is required to protect human lives, physical safety and property and it is difficult to obtain the consent of the person concerned.
(5) Where the handling of personal data is entrusted with in part or in whole to the extent necessary for achieving the objectives of use.
(6) Where personal data are disclosed as a result of business succession due to merger or other transactions.
(7) Where personal data are used jointly in accordance with Article 5 of this Basic Policy.
(8) Where the disclosure of personal data is allowed by other relevant laws and regulations.
12. Entrusting with the Handling of Personal Data
The Company may entrust an external entity with the handling of personal data in part or in whole to the extent necessary for achieving the objectives of use.
Examples of entrusted services
Examples of entrusted services
- Digitization of various questionnaires
- Information system development, management and maintenance
- Various printing and delivery
When entrusting an external entity with the handling of personal data in part or in whole, the Company will carry out the appropriate and necessary supervision of the external entity with which the handling of personal data is entrusted in order to ensure the safekeeping of such data.
13. Procedures for Accepting Request for the Disclosure of Personal Data
The Company will accept the request for the correction, addition, deletion, suspension of use, elimination and the cancellation of disclosure of personal data held by the company to a third party (hereinafter referred collectively as "disclosure") in accordance with the procedures specified by the company. For further details, please see the "Procedures for Filing Request for the Disclosure of Personal Information." The outline of these procedures is as follows:
(1) Filing request for disclosure: Your request for disclosure and inquiry are accepted at the Company's Information Desk.
(2) Documents required: Please fill in and submit the "Application for the Disclosure of Personal Information" specified by the Company.
(3) Confirming the identity of the person who is requesting disclosure or his or her proxy: Please submit the identification document specified by the Company.
(4) Collection of fee: A fee will be collected by the method specified by the Company when the objectives of use are filed or a request is made for disclosure.
14. Information Desk Responding to Inquiries About the Handling of Personal Information and Receiving Complaints
The Company appropriately responds to the inquiries about the handling of personal information and complaints. Please direct your inquiry or complain about the handling of personal information to:
Information Desk at Nikko Asset Management Co., Ltd.
Tel: +81 (0)3-6447-6000
15. Recognized Personal Information Protection Organization
The Company is a member of the following recognized personal information protection organizations.
Name of personal information protection organization and the customer inquiries window for complaint or consultation is as follows:
The Investment Trusts Association, Japan
The Investors' consultation department Tel: + 81 (0)3-5614-8440
Japan Investment Advisers Association
The Customer Inquiries for complaint or consultation Tel: + 81 (0)3-3663-0505
16. Review and Revision of the Basic Policy
The Company may, from time to time, review the contents of this Basic Policy and revise in response to the revision of relevant laws and regulations as well as changes in the information technology environment.
The Company will announce the revised Basic Policy by posting on our Web site or other method.
As used in the Basic Policy, the following terms shall have the following meanings:
(1) “Personal Information” means information concerning the living individuals (including the Company’s clients, employees and all related companies) which can identify specific individuals (including information which can be easily collated with other information to identify specific individuals).
(2) "Personal Information Data Base" means a collection of information including personal information systematically structured so that personal information on specific individuals can be retrieved by computer.
(3) "Personal Data" means personal information which forms a personal information data base.
(4) “Personal Data Held by the Company” means the personal data to which the Company has the rights to disclose at the request of the Person Concerned or his or her proxy, correct, add, delete, suspend the use, eliminate and cancel disclosure to a third party except for the data which will harm public interest or other interest if its existence is known and the data which will be deleted (not including the data which will be renewed) within 6 months.
(5) "Person Concerned" means a specific individual who can be identified by personal information.
(6) "Employees" means persons who are engaged in the Company's operations under direct or indirect supervision of the Company in its organization including not only those who are employed by the Company (executive officers, full-time employees, contract-based employees, temporary employees, part-time employees and casual workers) but also those who are not employed by the Company (directors, auditors and dispatched employees).
Announced April 1, 2005
Updated September 30, 2007
Updated May 1, 2008
Updated May 26, 2008
Updated October 1, 2009
Updated May 6, 2010
Updated April 1, 2011
Updated April 1, 2012
Updated July 2, 2012
Updated October 26, 2012
Updated January 4, 2013