Under Japan's APPI, personal data handlers must implement necessary security measures (Art. 23): organizational, human, physical, and technical. The 2022 reform mandated breach reporting to the PPC (Art. 26(1)) for sensitive data, financially damaging, malicious, or 1,000+ person breaches. Timeline: preliminary report within 3-5 days, full report within 30 days (60 for malicious). Individual notification also required (Art. 26(2)). Damages per person: ¥3-5K basic info, ¥5-15K credit cards, ¥10-30K medical data. Criminal penalties: up to 1 year imprisonment/¥1M fine for individuals, ¥100M for corporations (Art. 178, 184).
Corporate Liability for Data Breaches in Japan: Response Obligations and Damages
Key Takeaways
- ✓Reporting to the Personal Information Protection Commission is mandatory after a breach
- ✓Companies are obligated to implement data security management measures
- ✓Breach victims can claim damages from the responsible company
- ✓Employee training and access restrictions are fundamental prevention measures
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