Tokyo Play Therapy Room (hereinafter referred to as “TPTR”) has established the following Privacy Policy regarding users’ personal information (including clients, parents or legal guardians, referrers, and teachers).
This policy explains what personal information we collect, how we use, store, and share it, and how users may exercise their rights regarding their personal information.
TPTR recognizes the importance of protecting personal information and will properly acquire, use, and manage such information in accordance with the laws and regulations of Japan, including the Act on the Protection of Personal Information (Act No. 57 of 2003) (APPI).
1. Business Information
Tokyo Play Therapy Room
M2KSTAGE III 401, 3-3-13, Azabu Juban, Minato-ku, Tokyo, Japan
Representative: Mayumi Komuro
2. Definition of Personal Information
The term “personal information” refers to personal information as defined under the Act on the Protection of Personal Information (APPI).
It includes information relating to living individuals that can identify a specific person by name, date of birth, sex, address, telephone number, contact details, and other descriptions. It may also include sensitive personal information where relevant and collected with informed consent.
To better understand a child’s therapeutic needs, TPTR may collect information regarding the child’s family relationships, social and educational background, developmental history, medical information, and other relevant contextual information necessary for therapeutic assessment and care.
3. Method of Obtaining Personal Information
Personal information is collected through spoken and/or written communication.
We obtain personal information directly from parents, legal guardians, referrers, teachers, and, where appropriate, from the child. Where information is requested from other professionals involved in the child’s care, prior written consent from the parent(s) or legal guardian(s) is required.
4. Types of Documents Containing Personal Information
Referral / Consent Forms
Teachers and parents complete a referral and parent information form providing background information about the child, together with a signed consent form agreeing to the child’s participation in therapy.
These documents contain sensitive and confidential information and are collected based on informed consent for therapeutic, clinical, and research/statistical purposes.
Goodman’s Strengths and Difficulties Questionnaire (SDQ)
We collect statistical data regarding each child’s strengths and difficulties through the SDQ screening questionnaire. This provides baseline scores across five dimensions:
- Prosocial Behaviour
- Hyperactivity
- Emotional Symptoms
- Peer Problems
- Conduct Problems
For analytical and statistical purposes, all SDQ data is anonymised. Individual identifiers are removed, and the data cannot be traced back to an individual child.
Session Sheets (Clinical Notes)
Clinical notes are recorded following each therapy session. These records are used solely for therapeutic purposes, case management, professional supervision, and anonymised statistical analysis.
End Form and Casework Summary
At the conclusion of therapy, summary documentation may be completed. These records contain personal information relating to the child’s therapeutic process and outcomes.
5. Purpose of Use of Personal Information
Personal information is collected and used for the following purposes:
(i) To provide therapy services and related communication
(ii) To conduct assessment and clinical case management
(iii) To maintain accurate clinical records
(iv) To conduct anonymised research and compile statistical data
(v) To respond to inquiries and provide administrative support
(vi) To bill users for services
(vii) To share information with related professionals or family members when necessary and based on explicit consent
(viii) For PTUK to review therapists’ service quality and maintain a clinical evidence base
Personal information will not be used beyond these purposes without prior consent, except where required by law.
6. Storage and Security of Personal Information
Personal information is stored securely using Fortuna, a clinical record-keeping system provided by Play Therapy UK (PTUK) for registered therapists.
- Access is strictly limited to the therapist only.
- Data is stored in encrypted and password-protected systems.
- PTUK does not process identifying client information except where necessary for system maintenance.
- Personal information is not shared with third parties without explicit consent, unless required by law.
Data is stored on PTUK’s secure server located in the United Kingdom. Where personal data is transferred outside Japan or the EEA, appropriate safeguards are implemented in accordance with applicable data protection regulations.
7. Retention and Secure Disposal
Records are retained for five (5) years following the conclusion of therapy, in accordance with professional and legal standards in Japan.
After the retention period, records are securely destroyed using appropriate and safe disposal methods.
8. Rights of Parents and Legal Guardians
In accordance with APPI, parents or legal guardians have the right to:
- Request access to personal information
- Request correction of inaccurate information
- Request deletion of personal information where applicable
- Withdraw consent at any time
Requests must be submitted in writing and will be handled in accordance with Japanese law.
9. Safe Management of Personal Information
TPTR implements appropriate technical and organizational measures to protect personal information and prevent unauthorized access, alteration, leakage, loss, or damage.
10. Provision of Personal Information to Third Parties
TPTR will not provide personal information to third parties without the user’s consent, except where permitted or required by applicable laws and regulations.
Exceptions may include:
(i) When necessary to protect an individual’s life, body, or property and obtaining consent is difficult
(ii) When necessary for public health or the sound development of children
(iii) When required to cooperate with governmental authorities in accordance with law