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For example, the Guidelines on the Act on Protection of Personal Information in the Areas of Economy and Industry list examples of four types of measures: organizational measures, employee management, physical management, and technical measures.

If the applicant conducts any other business, the minister also considers whether that other business would impede the applicant’s fairness in terms of the proper handling of personal information.[47] An Authorized Personal Information Protection Organization must issue personal information protection guidelines concerning the specification of the purpose of utilization, security control measures, procedures for complying with individuals’ requests, and other matters.[48] For example, regarding the Internet business, the Internet Association Japan issued Personal Information Guidelines on Electronic Network Management in 1994, and updated this document after the APPI was enacted.[49] A data subject may file a complaint about the handling of personal information by a business operator with an Authorized Personal Information Protection Organization if the business operator is a member of the Organization.A business operator must exercise necessary and appropriate supervision over the employee who handles personal data to ensure the security control of the personal data.[22] The other is supervision over the trustee who handles personal data for the business.When a business operator handling personal information entrusts an individual or a business operator with the handling of personal data in whole or in part, it must exercise necessary and appropriate supervision over the trustee to ensure the security control of the entrusted personal data.[23] Ministry Guidelines provide more details on security measures.These acts may be punished by imprisonment of not more than one year or a fine of not more than 500,000 yen (about US,200).[58] In a 2005 case a person accessed a website without authorization through a security hole and copied the personal information of 1,200 users of the website.He was found guilty and sentenced to eight months’ imprisonment, but the sentence was suspended.[59] The APPI applies to business operators doing business in Japan.[60] The Japan Information Processing Development Corporation (JIPDEC) established the “Privacy Mark” system in 1998 upon instruction from the Ministry of International Trade and Industry (currently the Ministry of Economy, Trade and Industry, METI).

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[50] Where an Authorized Personal Information Protection Organization finds it necessary for assessing the complaint, the Organization may request that the business operator provide explanations or submit relevant materials.[51] It seems, however, that the ability of an Authorized Personal Information Protection Organization to resolve disputes between data subjects and business operators handling personal information is limited.

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