Law note · Japan
Act on the Protection of Personal Information, comprehensive regime and lawful basis
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_webtrains_modelsgenerates_contentdeploys_chatbotautomated_outreachhigh_risk_decisionsprocesses_voiceprocesses_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.