The "personal related information" in the revised personal Information Protection Law, the difference from anonymity, alias and the relationship with Cookie? Nikkei Cross Technology Active

　The discipline of "personal related information" has a particularly great impact on enterprises and institutions in the revised personal Information Protection Law implemented in April 2022, but its actual situation can not be said to have been widely recognized. What is personal related information and how it will be affected according to its regulations? in addition, various restrictions such as the Cookie of personal related information and the advertising ID of applications are increasing, but about how to look at it in the future.

　What is personal information? The personal Information Protection Act is defined as "information about the existence of individuals, personal information, pseudonym processing information and anonymous processing information that are inconsistent with each other". In general, identifiers such as Cookie (Cookie), IP address, terminal inherent ID, advertising ID, location information, reading resume, purchase resume, etc., are described as the corresponding cases.

　However, it is dangerous to use such a list of enumerated formulas to determine compliance. Because it is "personal-related information", for example, if it is an individual's smartphone, tablet, PC, other smart device, etc., all the information in the terminal should be considered to match. With regard to the logs that accompany communications, in the case of specific terminals and applications, it is also equivalent to personal information. These are protected as personal data in the General data Protection rules (General Data Protection Regulation,GDPR) of the European Union (EU).

　In Japan, personal information is protected in cases where "specific individuals can be identified (cases that are easy to check)". Therefore, it can be said that the other personal data is defined as personal related information.

　In addition, pseudonym processing information and anonymous processing information are excluded from personal related information. These are made from personal data. Therefore, as the object that should be protected, it shall be stipulated separately. Although it is possible to create personal information from personal data, when providing a third party, you need to agree to provide personal data as a third party. If the person you receive cannot identify a particular individual, you can regard it as personal-related information.

　Pseudonym processing information is prohibited from providing third parties. Therefore, even if it is not Kana processing information of personal data, it can not be provided to a third party as personal related information. Anonymous processing of information, because it is unnecessary, and even changes the consent of the person provided by the third party for the purpose, but there is little meaning of personally related information, even if anonymous processing of information, discipline inheritance so can not be treated like personal related information. Kana processing information and anonymous processing information are explained in the first time of this special, please refer to.

　Although often misunderstood, personal information is not the subject of the personal Information Protection Act because personal information has been identified. Certain discipline is imposed only when it is provided by a third party, in which case it is only the case of the processing of personal data as the object of the law.