In June 2020, the Japanese government introduced a set of amendments to the existing Act on the Protection of Personal Information (APPI). The Amended APPI will come into force on April 1, 2022.
The Amended APPI, amongst other things, includes rules relating to the processing of “personal referable information” (“PRI”) of Japanese users. The Amended APPI will require companies to, when providing PRI of Japanese users to a third party who will likely associate that data with 'Personal Information', confirm with the recipient that the recipient has obtained consent from data subjects to the recipient's processing, and record recipient's confirmation. PRI typically takes the form of information collected by identifiers that do not in themselves identify a specific individual (for example, a cookie ID) and are not stored alongside Personal Data (as defined in the APPI).
If you receive PRI (referred to in the policy as non-personally identifiable user information) relating to Japanese users from Google in connection with your use of Google's platform products, you must not merge that information with personally-identifiable information unless, prior to such processing, you have obtained all legally required consents from the user and have provided Google with accurate and complete information about the processing via the Google Ads Data Protection Terms Troubleshooter.
Your handling of PRI must conform to the requirements of the Amended APPI as well as the Platforms program polices by April 1, 2022.