Legal Notices

The particulars of personal information BKL processes, the purpose for which BKL processes such personal information, and the processing and retention period of such information shall be as follows:

1. Personal Information of Clients

2. Personal Information of Job Applicants for the Position of Professionals including Attorneys-at-Law

3. Personal Information of Job Applications (Employees)

BKL shall not disclose any personal information to a third party. BKL shall not provide any personal information to a third party, without obtaining prior consent from the data subject or being required to disclose such information pursuant the provisions of the applicable laws.

BKL shall not, in principle, entrust processing of personal information to any third party. If it is necessary to entrust processing of personal information afterwards, BKL shall comply with the obligations of a trustor under the applicable laws.

• ① The data subject may exercise his/her rights to protect his/her personal information, including access to, rectification, deletion, suspension of processing of personal information, and withdrawal of consent to provision of personal information, etc. in accordance with the applicable laws.
• ② Rights under Paragraph 1 may be exercised via an attorney-in-fact of the data subject, in which case a power of attorney is required to be submitted to BKL.
• ③ BKL will handle with the data subject’s exercise of rights immediately without delay in accordance with the applicable laws.

• ① If the retention period of personal information under Article 1 expires, BKL shall destroy relevant personal information within five days after the last day of such retention period, unless there is a justifiable reason. If personal information is deemed to be unnecessary because the purpose of processing of personal information is achieved, BKL shall, unless there is a justifiable reason, destroy relevant personal information within five days after it is deemed that processing of personal information is unnecessary. 
• ② BKL shall keep and manage such personal information or files as required to be preserved pursuant to the provisions of the applicable laws, separately from other personal information.
• ③ BKL shall destroy personal information upon obtaining approval from the Chief Privacy Officer of BKL.
• ④ Printouts and documents, etc. on which personal information is written shall be destroyed by shredding or incineration, and any personal information contained in an electronic file shall be permanently deleted in a way making it impossible to be restored. 

BKL shall take the following measures necessary to ensure safety in accordance with the applicable laws:

• 1. Physical protections: Restricting access to computing room, data room, and other storage places of personal information
• 2. Administrative protections: Establishment and implementation of internal privacy plan and regular education on privacy
• 3. Technical protections: Restricting access to personal information processing system, management of access power, installation of security program, and encryption of personal information

BKL’s Privacy Policy may be amended, and any amendment shall be disclosed in accordance with the applicable laws.  

① BKL has the following Chief Privacy Officer and working-level employees in accordance with the Personal Information Act:

② BKL has the following department and employees to receive and handle with requests for access to personal information:

BKL shall operate and manage image data processing equipment for safety management, facility security, and crime prevention, etc.

① BKL’s Administration Manager, responsible department and their phone numbers are as follows:   

② Access to the image data processing equipment of BKL shall be allowed to the following persons:  

• ① The image data processing equipment of BKL shall be turned on from 00:00 to 24:00 throughout the year. 
• ② BKL shall keep the image data for 30 days after being filmed. 
• ③ BKL shall keep the recorded image data at the Disaster Control Office of BKL in avi type file.

• ① BKL shall not use the personal image data created by the image data processing equipment for any purposes other than safety management, facility security and crime prevention. 
• ② BKL may check personal image data from time to time by playing a record file at the office of Office Administration Team, etc. where relevant personal image data is kept in order to investigate into a crime that took place within BKL. 
• ③ In case the retention or the processing period under Article 11(2) hereof expires, BKL shall delete the relevant file permanently in a technical method giving no chance of recovery, and if there are any printouts, etc. containing personal image data, BKL shall shred or incinerate such printouts, etc., unless otherwise specifically set forth in other applicable laws.
• ④ Any recorded image data shall not be used for any purposes other than specified for installation of image data processing equipment and access to such data shall be restricted only to the authorized persons.

• ① The data subject may request the manager of the relevant image data processing equipment or the Administration Manager of image data of BKL to allow access to or to confirm the existence of personal image data processed by BKL (“Access, Etc.”), in which case, the data subject shall file a written request setting forth the installation place, filming period, and purpose and reason of access, etc.
• ② Personal image data which can be requested by the data subject shall be limited to personal image data of the data subject or such personal image data as required for urgent need for protection of life, body and property.
• ③ Upon receipt of the request under Paragraph 1, BKL shall have the manager of the image data equipment verify the identity of the requesting person or his/her lawful attorney-in-fact via requesting submission of and checking his/her resident ID, driver’s license card, passport and other identification certificate. 
• ④ Additionally, BKL may permit access to the image data in each of the following cases:
  • 1. If required by special provisions of other laws;
  • 2. If provided in a blurred form from which a person is not identifiable, for media coverage via newspapers/broadcasts; 
  • 3. If necessary for investigation of crimes and indictment and maintenance of public prosecution; or
  • 4. If necessary for conduct of court proceedings.
• ⑤ Notwithstanding the provision of paragraph 3, in each of the following cases, the manager of the image data processing equipment may reject the request for Access, Etc. to the personal image data by the data subject, in which case the manager of the image data processing equipment shall within 10 days notify the data subject of the reasons of rejection in writing, etc.:
  • 1. If Access, Etc. results in significant hindrance in investigation of crime, maintenance of public prosecution and conduct of court proceedings;
  • 2. If personal image data has been destroyed since the retention period expired;
  • 3. If it has considerable technical difficulties to delete only the image data of the data subject, and Access, Etc. is highly likely to cause infringement of other persons’ right to privacy;
  • 4. If Access, Etc. causes significant hindrance in conduct of business of BKL; or
  • 5. If there are reasons to the interest of the public as reasonable to reject the request for Access, Etc. 
• ⑥ In the event BKL allows Access, Etc. in accordance with paragraph 3, and such Access, Etc. is likely to allow clear identification or infringe privacy of a person other than the data subject, BKL shall take protective measures to prevent identification of personal image data of a person other than the data subject in advance of Access, Etc. 
• ⑦ BKL shall record and manage each of the following particulars when taking measures under paragraph 3 or 4: 
  • 1. Name and contact point of the data subject requesting Access, Etc. of personal image data; 
  • 2. Name and content of personal image data files to which Access, Etc. is requested by the data subject;
  • 3. Purpose of Access, Etc. to personal image data;
  • 4. Specific reasons of rejecting Access, Etc. to personal image data; and 
  • 5. When a copy of personal image data is provided to the data subject, the content of the relevant image data and the reasons of such provision.

BKL shall take each of the following measures of assuring security of personal image data against being lost, stolen, disclosed, fabricated or damaged:

• 1. Physical protections: Restricting access to computing room, data room, and other storage places of personal image data
• 2. Administrative protections: Establishment and implementation of internal privacy plan and regular education on privacy
• 3. Technical protections: Restricting access to personal image data processing system, management of access power, installation of security program, and encryption of personal image data

In addition to the provisions on personal image data set forth in this Chapter, the provisions of Chapter 1 shall be applied unless being contrary to the properties of the image data processing equipment.