(Personal Information Protection Policy)
Tokyo Play Therapy Room (hereinafter referred to as “TPTR”) has established the following privacy policy regarding users’ personal information (users referred to clients, clients’ parents, referrers and teachers).This policy explains what personal information we collect, how we use and share it, and how you can manage your personal information. We recognize the importance of personal information and will properly acquire, use, and manage the personal information we handle in accordance with the laws and regulations concerning personal information (The Act on the Protection of Personal Information Act No. 57 of 2003).
1. business information
Tokyo Play Therapy Room
Address: 1-6, MotoAzabu 3 chome, Minato-ku, Tokyo, Japan, BLINK Roppongi, Private Office #22
Representative: Mayumi Komuro
2.Definition of Personal Information
The term “personal information” as used herein refers to “personal information” as defined in the Act on the Protection of Personal Information. It includes information on living individuals that can identify specific individuals by name, date of birth, sex, ethnic background, address, telephone number, contact information, and other descriptions, as well as information that can identify specific individuals by itself, such as the insurance number.
In order to be able to get ‘a better picture’ of the child’s therapeutic needs, we often collect relevant information about the child’s family, relationships, social and educational information and other significant information relating to the child. We may also want to take a case history which can help with the therapeutic process (if needed).
3.Method of obtaining personal information
We gain this information through spoken and/or written channels. We may also collect information about the contact details and child’s medical information. In addition to this, we need consent from the parent(s) to collect information from other relevant professionals working with the child.
Forms that contain personal information:
- Referral /Consent Form ：Teachers and Parents fill out referral / parent information form, providing background information about the child, along with a signed consent form, referring the child and stating that they are agreeing to the child being in therapy. These documents contain sensitive and confidential information.
- Goodman’s Strengths and Difficulties Questionnaire ：We collect statistical information relating to each child’s strengths and difficulties based on a screening questionnaire called SDQ. This provides a baseline score along five dimensions, namely, Prosocial, Hyperactivity, Emotional, Peer and Conduct. All data is collated anonymously and used for analytical and statistical purposes.
- Session Sheets ：Data related to each therapy session is recorded in the session sheets.
- End Form and Casework Summary form：These are forms that contain personal information of the child’s case information.
4. Where personal information is stored
Personal information we collect is stored in Fortuna. Fortuna is a highly secure system provided by Play Therapy UK (PTUK) for the registered therapists to record all users’ information. Details such as the user’s name and address are only processed by the therapist, for communication purposes. They are not processed by PTUK except, if relevant when our computer system is being repaired. Neither are they released by PTUK to any other organisation or person.
The securely processed data is stored on PTUK’s server located in the UK which is not directly connected to the Internet. The personal data may be transferred to, and stored outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, in which case the third country’s data protection laws will have been approved as adequate by the European Commission or other applicable safeguards are in place.
5.Purpose of Use of Personal Information
Our lawful basis for processing and storing personal information is one of legitimate interest. We need to process the child’s personal information in order to deliver a high quality Therapy service; we have a legitimate interest to process and store your child’s data. Therapists are legally bound to keep client information confidential and it is under this condition that we process and store personal information. We are obliged and committed to storing data safely. This is because every client is protected by the therapist-client privilege, and every individual is entitled to their privacy.
We also use the information provided by users within the scope of the following purposes. We will not collect information or use it for any other purposes without the user’s consent.
(i) To provide our services and related communications.
(ii) To respond to inquiries from users (including identification)
(iii) To contact the user as necessary for maintenance, important notices, etc.
(iv) To bill users for usage fees
(v) To provide information to related organizations, family members, and other related parties when deemed necessary and based on the user’s consent.
(vi) For PTUK to check therapists’ service quality and maintains clinical evidence base for research.
6. change of purpose of use of personal information
We will change the purpose of use of personal information only when it is reasonably deemed that the purpose of use is relevant before the change. In the event of a change in the purpose of use, TPTR shall notify the user of the changed purpose by the method prescribed by TPTR or publicly announce it on this website.
7. Purpose of Use of Pseudonymized Personal Information
We may disclose the process of our services for the purpose of academic research and training. In such cases, we will process the information appropriately and safely so that individuals cannot be identified, in accordance with the public announcement regarding pseudonymized information (Articles 41 and 42 of the revised Personal Information Protection Law).
8.Means of Communication with Users
In principle, we communicate with users by e-mail, telephone, and mail.
9. Safe management of personal information
TPTR shall implement appropriate measures to protect personal information, and shall take necessary and appropriate measures to prevent falsification, leakage, loss, or damage of personal information handled by TPTR, and to otherwise safely manage personal information.
10.Provision of Personal Information to Third Parties
We will not provide personal information obtained by us to any third party without the consent of the user. However, this does not apply to cases permitted under the Personal Information Protection Law or other laws and regulations.
(i) Cases in which the provision of personal information is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the individual
(ii) Cases in which the provision of personal information is especially necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the individual concerned.
(iii) Cases in which the provision of personal information is necessary for cooperating with a local government, or an individual or entity entrusted by local government to execute affairs prescribed by law, and in which obtaining the consent of the individual is likely to impede the execution of the affairs concerned
(iv) When the following matters are notified or publicized in advance and the TPTR notifies the Personal Information Protection Committee
(v) When the therapist is receiving a request for psychological testing or welfare services from the attending physician, and we may disclose information as necessary with the consent of the individual
(vi) When a therapist is unable to contact the user due to death or severe disability of the therapist, etc., a pre-designated substitute may access the user’s contact information and other personal information only for the purpose of contacting the user on behalf of the therapist
Notwithstanding the provisions of the preceding paragraph, in the following cases, the party to whom such information is provided shall not fall under the category of a third party.
(i) When we outsource all or part of the handling of personal information within the scope necessary to achieve the purpose of use
(ii) Cases in which personal information is provided as a result of the succession of business due to merger or other reasons
(iii) When a therapist receives a request for psychological testing or social services from an attending physician and discloses necessary information with that consent.
(iv) Cases in which personal information is used jointly with a specific person, and in which TPTR notifies the person in advance or makes readily accessible to the person the fact to that effect and the items of personal information to be jointly used, the scope of joint use, the purpose of use by the person using the information, and the name of the person responsible for managing the personal information.
(v) When publicizing the process of our services for the purpose of academic research and training, we will process the information appropriately and safely so that individuals cannot be identified, in accordance with the publicized matters concerning pseudonymized information (Articles 41 and 42 of the revised Personal Information Protection Law).
11.Procedures for Disclosure of Retained Personal Data
When we receive a request for disclosure of personal information from an individual, we will disclose such information to the individual without delay. However, we may not disclose all or part of the personal information in the following cases as stipulated in Article 25 of the Act on the Protection of Personal Information, and if we decide not to disclose the personal information, we will notify you to that effect without delay.
(i) When there is a risk of harm to the life, body, property, or other rights or interests of the user or a third party.
(ii) When there is a risk of significant hindrance to the proper conduct of our business due to the existence of personal information related to the therapist, or other disclosure of such information.
(iii) If disclosure of the information would violate any other laws or regulations.
Notwithstanding the preceding paragraph, in principle, TPTR will not disclose non-personal information such as historical information and characteristic information.
12.Correction, Suspension of Use, Deletion, etc. of Personal Information
When we receive a request or demand from a user for correction, addition, deletion, suspension of use, suspension of provision to a third party, or notification of the purpose of use of personal information in our possession, we will respond appropriately in accordance with the Personal Information Protection Law after confirming the identity of the person making such a request.
13.Improvement and Review of Handling of Personal Information
TPTR will conduct inspections of its handling of personal information from time to time and strive to improve and review its handling of personal information.
14.Disposal of Personal Information
When personal information is no longer necessary for the purpose for which it was collected, TPTR will delete or dispose of such information in a manner that is necessary and appropriate to prevent external loss, etc., to the extent necessary for the performance of its business.
15.Renewal of these Rules
TPTR reserves the right to change the Terms and Conditions at any time. Changes and explanations will become effective immediately upon posting to the website. If we make material changes to these Terms, we will notify you of the updates so that you are aware of what information we collect, how we use it, and under what circumstances we use or disclose it.
16. Provision of personal information to third parties located abroad
When we provide personal data to third parties located in foreign countries, we will take the necessary measures, including obtaining their consent, in accordance with applicable laws and regulations. We may provide personal information held by us to a third party in a foreign country in any of the following ways
(i) Provision based on the consent of the person in question
(ii) Provision to a third party in an EU/EEA member country or the UK, which is recognized in the “Enforcement Regulations of the Act on the Protection of Personal Information (Personal Information Protection Commission Regulation No. 3 of 2016)” as having a system for the protection of personal information at the same level as that of Japan.
What is GDPR?
The GDPR or the General Data Protection Regulation 2019/679 is a regulation in European Union (EU) law on data protection and privacy for all individual citizens of the EU and the European Economic Area. It also addresses the export of data outside the EU and EEA. As PTI’s registered headquarters are in the United Kingdom, all of its registered therapists and certified practitioners are required to adhere to the GDPR when handing client information and other sensitive data. In keeping with PTI’s ethical standards and data protection guidelines, this set out data protection policy will be applicable to any and all data collected and stored as part of our work.
(iii) Provision of personal information to a third party that is considered to be able to ensure that measures for the handling of personal information required by the Personal Information Protection Law of Japan are continuously taken.
17.Contact for consultation and complaints regarding handling of personal information
For inquiries regarding our handling of personal information, please contact the following
Address: 1-6, MotoAzabu 3 chome, Minato-ku, Tokyo, Japan, BLINK Roppongi, Private Office #22
Organization Name: Tokyo Play Therapy Room
E-mail address: tokyoplaytherapyroom@icloud.com
For details of information held by Play Therapy UK, please contact
Data Controller: Play Therapy UK
Adress: The Coach House Belmont Road Uckfield TN25 1BP.
Phone: 01825 761143
18. Privacy Policy Establishment Date
Established: April, 2024
19.Disclaimer
While every effort is made to ensure the accuracy of the information posted on our website, we shall not be liable for any damages incurred by the user or any third party as a result of the user’s use of our website.
20. copyright and portrait rights
The text, images, and all content on TPTR’s website are protected by copyright and portrait rights, and may not be used or diverted without permission.