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Frequently Asked Questions: private sector Treatment

Last Updated:
  • Q & amp; A is added as needed.
  • At the end of each answer, it says (Answer in X, 20 xx). There are some before August 2021, but this was answered on the Digital Agency website before the inauguration of Cabinet Office.

4-1 General

Q4-1-1 Does private sector also handle My Number?

A4-1-1

Even in private sector, it is necessary to obtain the My Number for employees and their dependents, enter it on the Income Tax Withholding Slip or the Application for Eligibility as an Insured Person for Social Insurance, and submit it to the administrative agency.

Also, you need to write your My Number on the payment records prepared by securities companies and insurance companies, payment records of manuscript fees, and so on.
(Updated June 2014)

Q4-1-2 Where can I check the forms (records and notification documents) in which my number needs to be entered?

A4-1-2

The details are stipulated in the ministerial ordinances related to the administrative affairs of social security, national taxes, local taxes, disaster prevention, etc. The forms related to national taxes and local taxes are published on the websites of National Tax Agency and Ministry of Internal Affairs and Communications, and the forms of notification documents related to social security are published on the website of Ministry of Health, Labor and Welfare.
(Updated June 2023)

Related Links

Q4-1-3 Can I use my My Number to manage the information of my employees and customers?

A4-1-3

My Number cannot be used for administrative procedures other than those prescribed by laws and ordinances or ordinance, such as social security system, tax system, and disaster response. In addition, private sector may not request employees or customers to provide My Number, or provide, collect, or store Specific Personal Information (Personal Information that includes My Number (see Q5-6)), except for those necessary for these procedures.

In addition, the My Number Card (Individual Number Card) can be used as an identification card for administrative work other than the procedures prescribed by laws and ordinances and ordinance, but in that case, the My Number printed on the back of the identity verification cannot be copied or copied. My Number Card

In addition, it is not considered to be a violation of the provisions of the My Number Act, such as restrictions on the provision of the My Number, that the My Number on the back of the My Number Card is unintentionally viewed or the My Number printed on the back of the My Number Card is unintentionally viewed when the My Number is presented as an identification card.
(Updated June 2023)

Q4-1-4 Can I entrust or re-entrust the work of handling my number?

A4-1-4

It is possible to entrust all or part of the work that handles My Number. In addition, the person who has been entrusted may re-entrust all or part of the work only if he / she has obtained permission from the person who originally entrusted the work.

In the case of entrustment or re-entrustment, necessary and appropriate supervision must be given to the person who has been entrusted or re-entrusted so that the security of personal information can be managed. The person who has been entrusted or re-entrusted will have the same obligation to appropriately handle the My Number as the person who has been entrusted.
(Updated June 2023)

Q4-1-5 Do even small businesses have to handle My Number and take measures to protect specific personal information?

A4-1-5

Small businesses are also required to handle employees' My Numbers in accordance with the social security and tax procedures stipulated by laws and ordinances, and must take measures to protect personal data as mentioned in the answer to Q4-4-1. My Number Act 's obligations apply to all businesses regardless of size.
(updated November 2017)

4-2 Acquisition of My Number

Q4-2-1 By when do employees and others need to obtain their My Number?

A4-2-1

Please obtain a statutory record containing your My Number by the time you submit it to an administrative agency.
(Updated June 2023)

Q4-2-2 What kind of procedures are required to obtain a My Number from employees or customers of financial institutions?

A4-2-2

When obtaining a My Number in writing (including electromagnetic records) directly from the person in question, please clearly indicate the Purpose of Use to the person in question and make a strict identity verification in order to prevent impersonation. See Q4-2-3 for the Purpose of Use and "4-3 identity verification" for the identity verification.
(Updated June 2023)

Q4-2-3 When I obtain a My Number for an employee, etc., do I have to clearly indicate the purpose of use? Also, where is it stipulated in the My Number Act?

A4-2-3

As stated in Q5-7, the Act on the Protection of Personal Information applies to Specific Personal Information (personal information that includes the My Number (see Q5-6)) unless there are special provisions in the My Number Act My Number Act. Therefore, if you directly obtain the My Number described in writing (including electromagnetic records) from the Principal, you must clearly indicate the Purpose of Use to the Principal in accordance with Article 21, Paragraph 2 of the Act.

It is possible to clearly indicate multiple purposes of use.
(Updated June 2023)

Q4-2-4 What method is appropriate for notification of the Purpose of Use of My Number?

A4-2-4

Notification of the Purpose of Use of the My Number can be made through the internal LAN in addition to the presentation of documents. However, in accordance with Article 21 of the Personal Information Protection Act and the guidelines for the same Act, it is possible to use the same method as for the acquisition of personal information that has been used in the past.
(Updated June 2023)

Q4-2-5 Is it possible to use Specific Personal Information obtained for one Individual Number Related Affairs for another Individual Number Related Affairs?

A4-2-5

If the My Number is used for administrative work that has not been specified as the Purpose of Use at the time the My Number is provided, the My Number will be used beyond the Purpose of Use specified in advance. In order to use the My Number for the relevant administrative work, it is necessary to clearly indicate the Purpose of Use and receive the My Number from the person in question again, or to change the Purpose of Use and notify or publicize the changed Purpose of Use to the person in question.

In cases where the Purpose of Use may be changed, Article 17, Paragraph 2 of the Personal Information Protection Act stipulates that "When an entity handling personal information changes the Purpose of Use, it shall not do so beyond the scope reasonably deemed to be related to the Purpose of Use before the change."

In addition, as described in Q4-2-3, when obtaining a My Number from an employee, there is no objection to obtaining and using the My Number by comprehensively clarifying the administrative work and purpose of use, such as procedures for withholding tax and health insurance.
(Updated June 2023)

Q4-2-6 In order to include the My Number in documents related to taxes, social security, etc., businesses need to obtain the My Number from their employees, etc. What should they do if the employees, etc. refuse to provide the My Number?

A4-2-6

Please make it known that listing your My Number on designated documents such as social security system and tax system is a duty stipulated by laws and ordinances or ordinance, and ask for it. If you still cannot receive it, please follow the instructions of the organization to which you are submitting the documents.
(Updated June 2023)

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Q4-2-7 The Company, whose workplaces are widely dispersed and several to several hundred employees are working at each workplace, conducts normal administrative work at (1) Administrative Centers that are integrated by region (several to several dozen administrative staff members are assigned) and (2) Administrative Departments at each workplace (several administrative staff members are assigned). In this case, regarding the acquisition of My Number, is it acceptable to designate each Administrative Center and Administrative Department in (1) and (2) as "Administrative Staff" and have them implement it?

A4-2-7

As an internal rule, there is no problem as long as you clarify the person in charge of handling administrative affairs, who is in charge, and who has confirmed it. Please set up a system where the company can confirm it when necessary.
(September 2015 response)

Q4-2-8 The scope of submission of a report of payment of real estate usage fees, etc. is that the total amount of payment to the same person during the year exceeds a certain amount specified by the Income Tax Act. If the total amount does not exceed the certain amount, is it possible to request the provision of a My Number?

A4-2-8

With regard to real estate lease contracts, it is generally considered that the amount to be paid during the year is already clear at the time of concluding the contract, such as when the monthly rent is specified in the contract contents. Therefore, if it is clear at the time of concluding the contract that the total amount of rent for the year does not exceed a certain amount specified by the Income Tax Act due to the contract contents, it is considered unnecessary to submit a payment record, and therefore it is not possible to request the provision of My Number at the time of concluding the contract.

On the other hand, since the contract was concluded in the middle of the year, even if the submission of the payment record is not required for the year, if the submission of the payment record is required for the next year, it is understood that the provision of the My Number can be requested for the preparation and submission of the payment record for the next year.
(September 2015 response)

Q4-2-9 If the payment amount has not been determined at the time of conclusion of the contract and the necessity of submission of the payment record is not clear, is it possible to request the provision of the My Number at the time of conclusion of the contract?

A4-2-9

Based on the legal relationship with the customer, in cases where Individual Number related affairs are expected to arise, it is understood that the provision of My Number can be received at the time of conclusion of the contract. After that, if it becomes clear that Individual Number related affairs will not arise, it is necessary to discard or delete My Number as soon as possible.
(September 2015 response)

Q4-2-10 If I open a so-called "general account (securities account / investment trust account)" instead of a specified account in order to trade stocks or investment trusts, can I request the provision of my My Number at the time of opening the account?

A4-2-10

Securities accounts and investment trust accounts are opened for stock and investment trust transactions, and it is assumed that Individual Number related affairs will arise based on stock and investment trust transactions in the future at the time of opening the account. Therefore, it is understood that the provision of My Number can be requested at the time of opening the account for so-called "general accounts."
(September 2015 response)

Q4-2-11 Is it possible for a temporary staffing agency to request the submission of a registrant's My Number at the time of temporary staffing registration?

A4-2-11

In principle, it is not possible to request the submission of a registrant's My Number simply because the registrant has been registered with a temporary staffing agency, whether or not he or she will be employed has not yet been determined, the occurrence of Individual Number-related administrative work is not expected, and the necessity of handling Individual Number-related administrative work such as withholding of salary has not yet been recognized.

However, if the opportunity to request the provision of My Number after registering is only at the time of identity verification, and it is recognized that there is a high probability that an employment contract will be established in the near future, such as determining the salary payment conditions for actual employment, it is understood that the provision of My Number may be requested in accordance with the case where the employment contract is established.
(September 2015 response)

4-3 identity verification

Q4-3-1 How can I make a identity verification when obtaining a My Number for employees, etc.? Also, how can I make a identity verification when obtaining a My Number by means other than face-to-face contact (by mail, online, or by phone)?

A4-3-1

When obtaining a My Number, it is necessary to confirm that the number is correct (number confirmation) and that the person who is actually carrying out the procedure is the correct holder of the number (identity confirmation).

  1. My Number Card (identification and identification)
  2. Electromagnetic Records in Lieu of Cards (Number Verification and Identity Verification)
  3. Copy of Residence Certificate with My Number (Number Confirmation) and Driver's License (Identity Confirmation)

However, if these methods are difficult, it is also permitted to confirm the number using a file created by identity verification in the past. In addition, if the person in charge of affairs using the Individual Number recognizes that it can be clearly determined that the person is the Individual Number due to the fact that they are in an employment relationship, it is also permitted not to require identity confirmation.

In addition to face-to-face contact, number verification and identity verification are also required when obtaining a My Number by mail, online, or phone. For more information, see Measures by Measures (PDF / 258 kb) (updated July 4, 2025).

When you receive a copy of your My Number Card when you obtain your My Number, it is acceptable to keep the copy in the card case provided at the time of My Number Card issue because the front side includes high-level personal information such as the organ donation declaration of intention column. However, please note that the back side must be a copy with your My Number displayed.

(Updated July 2025)

Q4-3-2 In the case of identity verification due to being in an employment relationship, is there any problem if the identification document at the time of employment is only a resume?

A4-3-2

A curriculum vitae alone is not sufficient for the identity verification at the time of employment. At the time of employment, it is necessary to confirm the My Number Act and tax laws of the National Tax Agency My Number Act, or by documents equivalent to those specified by the identity verification Notice (such as driver's licenses or student IDs with photographs).
(September 2015 response)

Q4-3-3 Do I need to have a copy of the identity verification document submitted when I obtain my My Number?

A4-3-3

As a general rule, in order to make a identity verification when obtaining a My Number face-to-face, it is necessary to "present" the identity verification document. Therefore, there is no need to request a copy of the identity verification document from the recipient of the lecture fee.

To make a identity verification when you obtain your My Number by mail, you need to send a copy of the identity verification document by mail.

In addition, in order to make a identity verification when obtaining a My Number online, it is possible to send a copy of the identity verification document by e-mail or use a Public Personal Authentication.

For more information, see Measures (PDF / 258 kb) (updated July 4, 2025).
(Updated June 2023)

Q4-3-4 How do I make a identity verification when I receive my My Number from my proxy?

A4-3-4

When you receive your My Number from a proxy, you need to confirm three things: (1) the proxy's authority, (2) the identity of the proxy, and (3) the number of the applicant. As a general rule

  1. For confirmation of the authority of representation, a copy of the family register, etc., in the case of a legal representative, or a letter of proxy in the case of a voluntary representative
  2. To confirm the identity of the agent, the agent's My Number Card, driving license, etc.
  3. To confirm the number of the applicant, the applicant's My Number Card, a copy of the certificate of residence with the My Number written on it, a notification card (*), etc.
    Check, but if these methods are difficult, other methods are allowed. For more information, see identity verification, Measures (PDF / 258 kb) (updated July 4, 2025).

* The "Notification Card" will be abolished on May 25, 2020. However, the Notification Card can still be used as a number verification document only if the name, address, etc. on the Notification Card match the information on the Resident Record.
(updated May 2020)

Q4-3-5 Do I have to make a identity verification even for a retired pensioner?

A4-3-5

Even retired pensioners must make a identity verification if they are provided with their My Number by themselves or their representatives.

It is possible to receive My Number information by mail, online, or telephone, but in that case, a identity verification (see Q4-3-1 and Q4-3-4) corresponding to the procedure is also required.

It is also possible to entrust the administrative work of identity verification (see Q4-3-7).
(Updated July 2014)

Q4-3-6 Do I have to make a identity verification every time I receive my My Number?

A4-3-6

Each time you receive your My Number, you need to make a identity verification. For example, if you have your employees submit an application form for a tax deduction for dependents that includes their My Number every year, you need to make a identity verification every time. However, for the second and subsequent number confirmations, if it is difficult for them to present their My Number Card, a copy of their certificate of residence that includes their My Number, or a notification card (*), you may use a method in which the business operator checks the My Number record obtained through the initial identity verification.

With regard to identification, if the person in charge of affairs using the Individual Number recognizes that it can be clearly determined that the person is the Individual Number due to the fact that they are in an employment relationship, it is not necessary to present documents for identification.

* The "Notification Card" will be abolished on May 25, 2020. However, the Notification Card can still be used as a number verification document only if the name, address, etc. on the Notification Card match the information on the Resident Record.
(updated May 2020)

Q4-3-7 Can I obtain my My Number and entrust the administrative work of identity verification?

A4-3-7

It is possible to entrust, but it is necessary to conduct necessary and appropriate supervision of the trustee in accordance with Article 11 of the My Number Act . When the trustee obtains the My Number from the person, it is necessary to clearly indicate the purpose of use as to what kind of administrative work the trustee will use it for.
(Updated June 2023)

Q4-3-8 When obtaining the My Number for the dependents of employees, does the business operator have to make a identity verification for the dependents?

A4-3-8

The identity verification for dependents varies depending on who is required to provide the dependent's My Number in each scheme. For example, in the year-end tax adjustment, employees are required to provide their employer with their dependent's My Number. Therefore, employees are required to provide their dependent's identity verification as a person in charge of Individual Number-related affairs. In this case, the employer is not required to provide the dependent's identity verification.

On the other hand, in the case of notification of Category 3 insured persons of the National Pension Plan, the spouses of employees (Category 3 insured persons) themselves are required to submit notification to the employer. Therefore, the employer is required to make a identity verification for the spouses. Normally, it is assumed that employees will submit notification to the employer on behalf of their spouses. However, in that case, employees will be required to provide their My Number as a proxy for their spouses. Therefore, the employer is required to make a identity verification for receiving My Number from the proxy.

It is also possible for businesses to entrust their employees with the administrative work involved in identity verification after receiving the My Number from their spouses.
(Responded in July 2014)

Q4-3-9 Can I make a copy of the identity verification documents (identity verification, notification card, identification documents, etc.) that I received when implementing the My Number Card measures under the My Number Act and keep it in the office?

A4-3-9

If you receive a copy of your identity verification documents when you obtain your My Number, you may keep the copy in order to keep a record of your identity verification. However, you need to take appropriate security control measures. However, you should dispose of your identity verification documents as soon as they are no longer needed after completing the necessary procedures.
(Updated June 2023)

Q4-3-10 If there is an error in the collected or provided My Number, is the responsibility of the business operator who is the person in charge of Individual Number Related Affairs extended to the business operator?

A4-3-10

There are no penal provisions for errors in the My Number. However, Article 16 of the My Number Act (number verification and identity verification) when receiving the My Number from the person in question, and Article 22 of the Personal Information Protection Act obliges the identity verification to make efforts to ensure accuracy.
(Updated June 2023)

Q4-3-11 Do I need to make a identity verification if I pay a lecture fee to a lecturer and continue to use it for the preparation of payment records for compensation, fees, contract money, and prize money in the next year or later?

A4-3-11

There is no need to make a identity verification again because the My Number provided for the administration of preparation of payment records of compensation, fees, contract money and prize money associated with the payment of lecture fees in the previous year can be used for the administration of preparation of payment records of compensation, fees, contract money and prize money associated with the payment of lecture fees continuously in the next year and thereafter.

However, if you receive your My Number again due to a change in your number, you will need to confirm your number and identity.
(September 2015 response)

4-4 Use and Safety Management

Q4-4-1 Is there anything that private sector should pay attention to when handling My Number?

A4-4-1

You will not be able to use your My Number beyond the scope of use specified by laws and ordinances or ordinance. You will also not be able to request the provision of your My Number or provide, collect, or store Specific Personal Information (Personal Information that includes your My Number (see Q5-6)) without due cause. In addition, when handling your My Number, you must take the necessary measures to appropriately manage your My Number, such as preventing leakage, loss, or damage. For specific measures, see the Guidelines (Personal Information Protection Commission website) from Personal Information Protection Commission.

In addition to receiving guidance, advice, recommendations, and orders from the Personal Information Protection Commission in the case of inappropriate handling of Specific Personal Information, in the case of providing a Specific Personal Information File (Personal Information File containing the My Number (see Q5-6)) containing confidential matters of individuals handled in relation to the business without justifiable grounds, it will be subject to punishment (see Q5-10).
(Updated June 2023)

Q4-4-2 Does private sector also need to conduct a Specific Personal Information Protection Assessment?

A4-4-2

The specific personal information protection evaluation is an evaluation by a person who intends to hold a specific personal information file (see Q5-6) regarding the risk and impact of leakage of specific personal information.

The Specific Personal Information Protection Assessment is required to be conducted by (1) administrative organs, (2) local public entities, (3) incorporated administrative agencies, etc., (4) local incorporated administrative agencies, (5) Japan Agency for Local Authority Information Systems, and (6) business operators engaging in information collaboration (refers to those listed in My Number Act My Number Act other than those listed in (1) to (5), and to be specific, health insurance associations, etc.).

For this reason, private sector does not need to conduct the Specific Personal Information Protection Assessment, except for health insurance associations and other organizations that coordinate information. However, this does not preclude from conducting the Specific Personal Information Protection Assessment at its own discretion. For details on the Specific Personal Information Protection Assessment, please refer to the section of the Personal Information Protection Commission website.
(Updated June 2014)

Q4-4-3: Instead of managing the My Numbers of employees and their dependents for each type of administrative work, such as tax and social security, is it possible to establish a new system for managing and collecting My Numbers and to link this system with existing systems for administrative work?

A4-4-3

As described in Q4-2-3, it is necessary to clearly indicate the purpose of use when obtaining a My Number from an employee, and it is necessary to take measures such as controlling the linkage with the existing system so that the My Number cannot be used beyond that scope.
(Updated June 2014)

Q4-4-4 "Clarification of the person in charge of handling administrative affairs" does not have to be based on the name of the individual, such as clarification by role or affiliation?

A4-4-4

It is considered sufficient to clarify the person in charge by the name of the department (XX Division, XX Section, etc.), the name of the office work (XX person in charge of office work), etc. However, if the scope of the person in charge of office work cannot be clarified by the name of the department, etc., it is considered necessary to designate the person in charge of office work, etc.
(September 2015 response)

Q4-4-5 Instead of newly creating handling regulations, etc. concerning the protection of specific personal information, is it possible to review the existing handling regulations, etc. concerning the protection of personal information and add the handling of specific personal information?

A4-4-5

If there are existing handling regulations, etc. related to the protection of personal information, it is considered possible to add the handling of specific personal information.
(September 2015 response)

Q4-4-6 Even if a customer's My Number is legally stored, is it necessary to request the provision of the My Number each time a new contract is concluded?

A4-4-6

The legally stored My Number can be used for Individual Number related affairs based on a new contract without being provided with a new My Number within the scope of the initially specified Purpose of Use.
(September 2015 response)

Q4-4-7 Businesses are required to obtain My Numbers from their employees and use them for administrative work such as tax and social security. Do they have to stipulate the handling of My Numbers in their work rules?

A4-4-7

Businesses are required to receive My Numbers from their employees after clearly indicating the Purpose of Use in order to carry out the procedures for tax system, social security system, etc. specified by laws and ordinances or ordinance. As with the acquisition of personal information that has been conducted in the past, this can be done by providing notification via the internal LAN, presenting documents stating the Purpose of Use, or clearly stating it in the work rules.

It is only one of the methods to stipulate the handling of the My Number in the work rules, and it is not necessarily necessary to stipulate it in the work rules as a method to be widely known, but I would like each business operator to make a decision on which method to adopt specifically.

In addition, regarding the relationship between the My Number and the labor-related laws and ordinances, please check the in the "Request for the Cooperation of Employers and Employees in Entering the My Number (Individual Number) in Social Security and Tax Procedure Documents," , a document prepared by Ministry of Health, Labor and Welfare (Ministry of Health, Labor and Welfare website).
(Updated June 2023)

4-5 Provision of My Number

Q4-5-1 When an employee is seconded or transferred to a subsidiary, etc., is there any problem with providing the employee's specific personal information (personal information including My Number) to the company to which the employee is seconded or transferred?

A4-5-1

My Number Act of the My Number Act, if an employee is seconded or transferred to another company and the employee has given consent, the business operator before the secondment or transfer may provide the business operator to which the employee was seconded or transferred with the Specific Personal Information of the employee to the extent necessary for processing the Individual Number related affairs.

In addition, a business operator before secondment or transfer is required to obtain consent from the relevant employee after the decision on the secondment or transfer of the employee is made, after clarifying the specific provider of the Specific Personal Information.
(Updated June 2023)

Q4-5-2 Is it okay to provide the My Number to the successor of the business when there is a succession of the business due to a merger?

A4-5-2

The succession of businesses due to a merger, etc. falls under Article 19, Item 6 of the My Number Act My Number Act.
(Updated June 2023)

Q4-5-3 May I provide the My Number of the employee or his / her dependent obtained by the employer to the health insurance society to which the employee belongs?

A4-5-3

If an employer is required to provide the My Number of employees and their dependents to the Health Insurance Association in accordance with laws and ordinances regulations such as the Health Insurance Act, it is possible for the employer to provide the My Number to the Health Insurance Association, which is in charge of Individual Number usage affairs, because the employer is in charge of Individual Number related affairs.

When a business operator obtains a My Number from an employee, it is necessary to clearly indicate that the My Number will be used for Individual Number related affairs related to health insurance.
(Updated June 2023)

Q4-5-4 How should we handle the spin-off?

A4-5-4

In the case of a spin-off, there is no need to re-acquire, and it is possible to provide the acquired Specific Personal Information to the necessary extent. Article 19, Item 6 of the My Number Act
(Updated June 2023)

Q4-5-5 While the Group as a whole is trying to improve efficiency by managing and operating human resource information, it is inefficient to manage My Number only on an individual company basis within the Group. Please tell us the reason why it is considered on an individual company basis.

A4-5-5

My Number Act of the My Number Act, activities that go beyond organizations or individuals, such as from individuals to corporations or from corporations to corporations, are categorized as "provision to third parties." The Personal Information Protection Act allows shared use, but the My Number Act does not allow shared use based on Article 27, Paragraph 5, Item 3 of the Personal Information Protection Act. Even if a company is within the Group, if it is a different company, it falls under third party provision, so it cannot provide My Number unless it is permitted by Article 19 of the My Number Act. However, handling of My Number can be outsourced. For example, it is possible to outsource to the head office of the Group, where the head office performs identity verification, and receive provision from the head office based on Article 19, Item 6 of the My Number Act.
(Updated June 2023)

Q4-5-6 Can I use a certificate of income and withholding tax for employment income with my My Number printed on it for borrowing (housing loan) related to the acquisition of housing?

A4-5-6

On October 2, 2015, Article 93 of the Ordinance for Enforcement of the Income Tax Act was revised with respect to the Withholding Record of Employment Income for issue of the Principal, and the Withholding Record without the My Number of the Principal and Dependents will be used for issue.

In addition, when using a certificate of income and withholding tax containing the My Number based on the request for disclosure under Article 33 of the Personal Information Protection Act for borrowing related to the acquisition of housing (housing loan), etc., it is necessary to take measures such as masking to the extent that the My Number portion cannot be restored.
(Updated June 2023)

Q4-5-7 If I do not include my My Number, can I send a copy of the payment record to the person in question?

A4-5-7

If all My Numbers, including the My Number of the Principal, are not recorded or masked to the extent that they cannot be restored, it is possible to send a copy of the payment record, etc. to the Principal without the request for disclosure based on Article 33 of the Personal Information Protection Act, because the provision restriction under the My Number Act is not applied.
(Updated June 2023)

4-6 Disposal of My Number

Q4-6-1 Please tell me about the timing of the disposal of an employee's My Number.

A4-6-1

When there is no longer a need to handle Individual Number related affairs, and the storage period specified by the laws and ordinances of jurisdiction has passed, the My Number must be disposed of or deleted as soon as possible.

With regard to the period between the time when disposal becomes necessary and the time when the disposal work is carried out, the business operator should make a decision by taking into account the safety and administrative efficiency of the retention of the My Number and Specific Personal Information, such as by carrying out disposal at the end of each fiscal year.
(September 2015 response)

Q4-6-2 How long is the period between the time when My Number becomes necessary to be disposed of and the time when the disposal work is carried out?

A4-6-2

The period from the time when disposal becomes necessary to the time when disposal work is carried out should be determined by the business operator, taking into account the safety and administrative efficiency related to the retention of the My Number and Specific Personal Information, such as disposing at the end of each fiscal year.
(September 2015 response)

Q4-6-3 Is it possible to delete the My Number when the contract relationship ends in order to avoid time-limited management of the storage period of the My Number?

A4-6-3

It is considered that items that are required to be retained for a certain period of time by the competent laws and ordinances cannot be deleted when the contractual relationship ends.
(September 2015 response)

4-7 Penalties

Q4-7-1 Are penal provisions applied even in cases where My Number or Specific Personal Information, etc. has been unintentionally leaked (e.g., cases where information has been leaked through cyberattacks, etc.)?

A4-7-1

In the case of leakage of My Number or Specific Personal Information due to negligence, penalties will not be applied immediately. However, depending on the type of leakage, guidance, advice, recommendations, or orders may be received from the Personal Information Protection Commission, and if you violate the orders, penalties may be applied. The above is the case of criminal penalties, but in the case of civil cases, there is a possibility that you will be claimed for damages even if it is due to negligence.
(Updated June 2023)

Reference

Since the interpretation and application of criminal laws and regulations are under the authority of courts and investigative authorities, it is a general theory, but in the event of leakage of Specific Personal Information, if the Specific Personal Information meets the constituent requirements prescribed in Articles 48 to 57 of the My Number Act , there is a possibility of punishment, but these penal provisions do not meet the constituent requirements if there is no intention.

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