Law note · Japan

Act on the Protection of Personal Information, comprehensive regime and lawful basis

cite Act No. 57 of 2003, as amended by Act No. 37 of 2021, Arts. 15, 20, 25 stage IN FORCE in force since 2022-04-01 kind Comprehensive regime binds public and private bodies reviewed 2026-08-29

What it requires

  • An app that collects, uses, or discloses the personal data of an individual in Japan must give notice of, or publicly disclose, its purpose of use before or promptly after collection, must not acquire the data by wrongful or deceptive means, and must confine use to the stated purpose unless a statutory exception or the data subject's consent applies.

When LexLint raises it

  • crawls_web
  • trains_models
  • generates_content
  • deploys_chatbot
  • automated_outreach
  • high_risk_decisions
  • processes_voice
  • processes_biometrics

What we found

The Act on the Protection of Personal Information (APPI) is Japan's single comprehensive personal-data statute, covering private businesses (Chapter IV), administrative organs (Chapter V), and independent administrative agencies since the 2021 merger amendment folded the former separate acts into one text. Lawful basis is purpose-of-use notice under Art. 15 plus a general prohibition on wrongful acquisition under Art. 20(1); there is no General Data Protection Regulation (GDPR)-style enumerated legal-basis list.

APPI regulates businesses handling personal information directly rather than a controller and processor split, and Art. 25 imposes supervision duties over any entrusted processor.

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