(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 persons 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 an insurance number.
In order to better understand the child’s therapeutic needs, we often collect relevant information about the child’s family, relationships, social and educational background, and other significant information related to the child. We may also take a case history if necessary to help with the therapeutic process.
3. Method of Obtaining Personal Information
We collect information through spoken and/or written channels. We may also gather details about the child’s contact information and medical history. Additionally, 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 a referral/parent information form, providing background information about the child, along with a signed consent form, referring the child and agreeing to the child being in therapy. These documents contain sensitive and confidential information.
- Goodman’s Strengths and Difficulties Questionnaire (SDQ): We collect statistical data regarding each child’s strengths and difficulties based on a screening questionnaire called the SDQ. This provides a baseline score across five dimensions: 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 session sheets.
- End Form and Casework Summary Form: These forms contain personal information regarding the child’s case.
4. Where Personal Information Is Stored
Personal information we collect is stored in Fortuna, a highly secure system provided by Play Therapy UK (PTUK) for registered therapists to record all user information. Details such as the user’s name and address are only processed by the therapist for communication purposes and are not processed by PTUK except when necessary during system maintenance. These details are not released by PTUK to any other organization or person.
The securely processed data is stored on PTUK’s server, located in the UK, which is not directly connected to the Internet. Personal data may be transferred 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 such cases, the third country’s data protection laws will have been approved as adequate by the European Commission, or other applicable safeguards will be in place.
5. Purpose of Use of Personal Information
Our lawful basis for processing and storing personal information is legitimate interest. We need to process the child’s personal information to deliver high-quality therapy services; we have a legitimate interest in processing and storing this 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 committed to safely storing this data because every client is protected by the therapist-client privilege, and every individual is entitled to their privacy.
We will use the information provided by users within the scope of the following purposes. We will not collect or use information 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, based on the user’s consent.
(vi) For PTUK to check therapists’ service quality and maintain a 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 relevant to the original purpose. In the event of a change, 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 academic research and training purposes. In such cases, we will process the information appropriately and safely, ensuring 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 via email, telephone, and mail.
9. Safe Management of Personal Information
TPTR shall implement appropriate measures to protect personal information and take necessary and appropriate steps to prevent falsification, leakage, loss, or damage of personal information handled by TPTR, and to ensure its safe management.
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, except in cases permitted by the Personal Information Protection Law or other laws and regulations.
Exceptions include: (i) When the provision of personal information is necessary for protecting an individual’s life, body, or property and it is difficult to obtain the individual’s consent.
(ii) When the provision of personal information is necessary for improving public health or promoting the sound growth of children, and obtaining consent would be difficult.
(iii) When personal information is required for cooperation with local governments or entities entrusted by the government to execute affairs prescribed by law, and obtaining consent would impede the execution of such affairs.