Act on the Protection of Personal Information, contact particulars in pseudonymized and anonymized information
Act No. 57 of 2003, as amended by Act No. 56 of 2026, Arts. 42(4), 46-2
A comprehensive regime rule binding private bodies.
- Audit expectation
- none
As of .
What it requires
- If you handle pseudonymized personal information or anonymized personal information that contains a description Article 2(8) lists, such as the location of a person's residence or workplace, do not use it by a method likely to encourage or induce an illegal or unjust act and do not acquire it by deceit or other wrongful means (Articles 42(4), 46-2 and 31-2).
These lines are LexLint's reading of the law's text, as of .
What it makes you log
Logging duty
Article 42(4) and Article 46-2 apply the ban in Article 31-2 on using contactable personal-related information to encourage or induce an illegal or unjust act, and on acquiring it by deceit or other wrongful means, to pseudonymized and anonymized personal information that carries contact particulars. A ban on use and acquisition requires no log, register or record. The Act is enacted and not yet in force.
- Kind
- None
- As of
What this law does
Article 42(4), inserted by Act No. 56 of Reiwa 8, applies Article 31-2 to a business handling pseudonymized personal information in its handling of pseudonymized personal information that contains the descriptions Article 2(8) lists, including information that can easily be collated with other information to identify those descriptions.
Article 46-2, inserted by the same Act, applies Article 31-2 in the same way to a business handling anonymized personal information in its handling of anonymized personal information that contains those descriptions. Article 31-2 provides that a business must not use contactable personal-related information by a method likely to encourage or induce an illegal or unjust act, and must not acquire it by deceit or other wrongful means. The Act comes into force on a day a Cabinet Order sets within two years of its promulgation.
When LexLint raises it
When your app profile says your app processes personal data.