Contact Confirmation Application Privacy Policy

Contact Confirmation Application Privacy Policy

【Notification of a Revision to the Privacy Policy on December 1, 2021】
The processing numbers required when a person who has tested positive for COVID-19 registers the result of his/her positive test in the contact confirmation application (hereinafter “the App”) have not been retained in the data after the positive registration or after the end of the expiration date previously. However, we have now changed this and shall retain processing numbers as data in the cloud of the management system that issues processing numbers to respond to inquiries. Accordingly, we have revised the privacy policy in line with this.

【Notification of a Revision to the Privacy Policy on December 15, 2020】
The App has until now employed a system that notifies users who may have been in contact with a person who has tested positive for COVID-19 over the past 14 days when a user registers that he/she has tested positive. The Ministry of Health, Labour and Welfare has now revised this from the perspective of ensuring consistency with the proactive epidemiological investigations conducted by health care centers. Therefore, we have started distributing a revised version of the App. In this version, a user who has tested positive for COVID-19 inputs the date of the onset of symptoms or the test date. The application then notifies users who may have been in contact with the said user who has tested positive for COVID-19 from approximately two days before that onward (within the infectable period). Accordingly, we have revised the privacy policy in line with this. The main changes are as follows.
  • We have stated that there is a system which notifies users that they may have been in contact with a person who has tested positive for COVID-19 within the infectable period as the system of the App. We have stated that this system works by the person who has tested positive for COVID-19 inputting the date of the onset of symptoms or the test date in addition to the processing number and then sending the daily key generated from approximately two days before that onward (within the infectable period) to the notification server.   
  • We have specified that this only applies to the daily key generated within the infectable period in the information obtained by the Ministry of Health, Labour and Welfare using the App.   
  • We have specified that the Ministry of Health, Labour and Welfare will not obtain or provide to other application users the date of the onset of symptoms or the test date input in the App.
   
〇 Contact Confirmation Application Privacy Policy
 
The Ministry of Health, Labour and Welfare is committed to complying with all applicable laws and regulations, and giving maximum consideration to users’ privacy, in the provision of the App. To that end, the App is provided in accordance with the following Privacy Policy.
 
1 System of the App
A. In an App-Installed Device (a smartphone device in which the App is installed; the same applies hereinafter) of an App User (a person who uses a service provided by the App by using the App; the same applies hereinafter), a Daily Key (an identifier which, in the App-Installed Device, is unique to that Device and which is changed every 24 hours; the same applies hereinafter) is automatically generated and recorded.
B. In the App User’s App-Installed Device, a Contact Code (an identifier which is generated in an App-Installed Device on the basis of the Daily Key and which is changed every 10 minutes; the same applies hereinafter) is automatically generated and recorded.
C. Only when Bluetooth is enabled in the App-Installed Devices of the App User and another App User who is in a state of proximity with said App User, using Bluetooth, (i) the Contact Code generated and recorded in the App User’s own App-Installed Device is automatically provided to and recorded in the App-Installed Device of the other App User in a state of proximity with said App User, and (ii) the Contact Code generated and recorded in said other App User’s App-Installed Device is automatically provided to and recorded in the App User’s own App-Installed Device.
D. In the event that the App User has determined that they are a Positive Tester (a person who has tested positive for COVID-19; the same applies hereinafter), when said App User registers that they are a Positive Tester in the App, (i) said App User inputs, to their own App-Installed Device, (A) a Processing Number (a number without any special meaning, which is issued randomly and communicated to an App User from a Management System in the event that the App User has been determined to be a Positive Tester; the same applies hereinafter) sent to said App User’s mobile telephone number or email address, which has been registered separately with the Management System (a COVID-19 infected person information identification and management support system, operated by the Ministry of Health, Labour and Welfare and used by prefectures and cities where public health centers are located, for the purpose of managing information of Positive Testers for COVID-19 and people who have been in close contact with Positive Testers; the same applies hereinafter), and (B) the date of the onset of symptoms in the event the said Positive Tester has symptoms of COVID-19 or the test date in the event the said Positive Tester has no symptoms of COVID-19 (hereinafter the period from approximately two days before the date of the onset of symptoms or the test date onward shall be referred to as the “Infectable Period”), (ii) whether or not the input Processing Number is a Processing Number issued to a Positive Tester is verified with the Management System from said App User’s App-Installed Device via a Notification Server (a server, managed by the Ministry of Health, Labour and Welfare, which is linked to the App-Installed Device and which has a function for, when the App User has accepted necessary matters, managing the Daily Key registered from the App-Installed Device and providing said Daily Key to the App-Installed Device of another App User under a certain condition or conditions; the same applies hereinafter), and (iii) a response indicating whether or not the verified Processing Number is a Processing Number issued to a Positive Tester is provided to the Notification Server from the Management System.
E. In the event where, as a result of said verification, a response indicating that the verified Processing Number is a Processing Number issued to a Positive Tester has been made, the Daily Key recorded in the App-Installed Device of the Positive Tester (only those generated within the Infectable Period of the said Positive Tester) is automatically provided to the App-Installed Device of said other App User via the Notification Server. In the App-Installed Device of said other App User, Contact Codes recorded in the App-Installed Device of said other App User within a maximum of the last 14 days are searched, and in the event where it is determined that a Contact Code equivalent to Contact (a state within which a person has been approximately 1 meter of another person for no less than 15 minutes; the same applies hereinafter) is recorded, a notification indicating that said other App User may have been in contact with an unspecified Positive Tester within the Infectable Period is made in the App-Installed Device of said other App User.
 
2 Information which is and is not collected by the Ministry of Health, Labour and Welfare using the App
(1) Information which the Ministry of Health, Labour and Welfare collects
・ The Ministry of Health, Labour and Welfare may use the App to collect the following information.
A. The Processing Number of the Positive Tester in the process of 1-D described above.
B. The Daily Key of the Positive Tester in the process of 1-E described above (only those generated within the Infectable Period of the said Positive Tester).
C. The operating information of the App necessary to improve the App in 1 above (including details of the processing performed by the App, the time the processing was performed, whether the processing was a success or failure, information referred to when performing processing, information output as results of processing and the state at the time of processing etc., but not including the processing number, Daily Key or Contact Code) and information relating to the usage environment of the App (this refers to the version of the App being used, the OS of the usage device, the OS version and the device model; hereinafter, together with the operating information, referred to as “Operating Information etc.”).
(2) Information which the Ministry of Health, Labour and Welfare does not collect
・ The Ministry of Health, Labour and Welfare does not use the App to collect information aside from the information listed in (1) above (including, but not limited to, the information listed below).
・ The Ministry of Health, Labour and Welfare does not use the App to collect the App User’s name, date of birth, gender, address, telephone number, email address, device location information, or any other information which enables the App User to be personally identified, and the IP address, MAC address, host name or other information which may identify an individual App-Installed Device.
・ Contact Codes are recorded in an encrypted state within each App User’s App-Installed Device. Contact Codes cannot be known by any parties, including App Users, and the Ministry of Health, Labour and Welfare does not collect this information.
・ The Ministry of Health, Labour and Welfare does not use the App to collect information which enables a Positive Tester to be personally identified. As such, when, with the consent of a Positive Tester, another App User receives, through the App, a notification of information pertaining to contact with said Positive Tester within the Infectable Period which has occurred in the previous 14 days, the Ministry of Health, Labour and Welfare does not provide, to the person receiving said notification, any information which enables said Positive Tester to be personally identified.In addition, the Ministry of Health, Labour and Welfare does not obtain or provide to other App Users the date of the onset of symptoms or the test date input in 1 D (i) (B).
・ The Ministry of Health, Labour and Welfare does not use the App to collect information which enables a person who has received a notification that they may have come into contact with a Positive Tester within the Infectable Period to be personally identified. As such, the Ministry of Health, Labour and Welfare does not use the App to provide, to said Positive Tester, information which enables the person who has received the notification to be personally identified.
・ The Ministry of Health, Labour and Welfare does not use the App to collect information pertaining to relationships, dates and/or times of Contact, etc., between a Positive Tester and another App User who has received a notification that they may have come into contact with the Positive Tester within the Infectable Period.
 
3 Purposes for and methods through which Ministry of Health, Labour and Welfare uses information collected via the App
(1) Processing Number
・ The Ministry of Health, Labour and Welfare uses the Processing Number of the Positive Tester, described in 2(1)A and obtained by the Ministry of Health, Labour and Welfare, to ensure that a person who uses the App but is not a Positive Tester is not registered as having tested positive. In other words, the system is such that a Processing Number, which has been obtained from the Notification Server of the Ministry of Health, Labour and Welfare by an App User who is a Positive Tester inputting the Processing Number in their App-Installed Device after the Processing Number has been issued to said Positive Tester from the Management System when said Positive Tester registers, in the App, that they are a Positive Tester, is used to verify whether or not the input Processing Number is a Processing Number that has been issued to a Positive Tester, and the Positive Tester is only registered as having tested positive upon it being confirmed that said Processing Number is a Processing Number that has been issued to a Positive Tester.
・ The Processing Number shall be retained in the Management System upon completion of the confirmation as to whether or not the input Processing Number has been issued for a Positive Tester.
(2) Daily Key
・ The Ministry of Health, Labour and Welfare uses the Daily Key of the Positive Tester, described in 2(1)B and obtained by the Ministry of Health, Labour and Welfare(only those generated within the Infectable Period of the said Positive Tester; hereinafter the same in this section (2)), to notify another App User that they may have been in a state of Contact with an App User who is a Positive Tester within the Infectable Period in the previous 14 days. In other words, the system is such that the Daily Key of an App User who is a Positive Tester is obtained from the Notification Server of the Ministry of Health, Labour and Welfare upon said Positive Tester being registered as having tested positive and provided to the App-Installed Device of another App User, and in the event where an automatic search of Contact Codes recorded in said terminal has returned a Contact Code equivalent to Contact, a notification of potential Contact with a Positive Tester within the Infectable Period is provided to said other App User.
・ In the event where an App User who is a Positive Tester desires to be registered as having tested positive, the Ministry of Health, Labour and Welfare will, in advance and through the App, obtain explicit consent to (a) the Daily Key recorded in said App User’s own App-Installed Device being provided to another App User’s App-Installed Device and (b) another App User who has been in a state of Contact with said App User within the Infectable Period being able to know that said other App User may have been in Contact with an unspecified Positive Tester within the Infectable Period without receiving information which enables said Positive Tester to be personally identified.
・ The Ministry of Health, Labour and Welfare will not use the obtained Daily Key for any purposes other than the stated purpose. All Daily Keys (including those generated outside the Infectable Period of the said Positive Tester) are automatically invalidated 14 days after being generated in the App-Installed Device.
(3) Operating Information etc.
・ The Ministry of Health, Labour and Welfare will use the Operating Information etc. described in 2 (1) C that has been obtained by the Ministry of Health, Labour and Welfare to promptly take the necessary measures to improve the App based on information relating to the possibility of a malfunction in the App etc. sent by the App User.
・ The Ministry of Health, Labour and Welfare will not obtain Operating Information etc. unless the App User feels there is a possibility of a malfunction in the App etc. and then voluntarily sends Operating Information etc.
・ In the event an App User who has sent Operating Information etc. further voluntarily cooperates with an investigation into the malfunction in the App etc., the operating information ID (the operating information ID is a random number assigned to the Operating Information etc. and refers to a code used only to link an inquiry to Operating Information etc.) will be conveyed to the support desk described in 6 via e-mail. The Ministry of Health, Labour and Welfare will use the operating information ID to link and then manage inquiries received at the support desk and Operating Information etc. The Ministry of Health, Labour and Welfare will obtain explicit consent in advance in the App to perform such information management.
・ The Ministry of Health, Labour and Welfare will not use Operating Information etc. for any other purposes. The Operating Information etc. will be immediately deleted from the server upon the completion of the investigation into the malfunction that pertains to the said Operating Information etc.
 
4 Retraction of Consent and Deletion of Records
・ Consent pertaining to the use of the App can be retracted at any time by deleting the App from the App-Installed Device. In the event that the App User has retracted consent through the stated method, all information of the App recorded in the App User’s App-Installed Device will be irrecoverably deleted.
・ Information pertaining to proximity with other App Users recorded in the App-Installed Device (e.g., Contact Codes recorded in the App-Installed Devices of other App Users) are recorded in an encrypted state and are automatically invalidated after 14 days.
・ The operating information recorded in App-installed Devices will be automatically deleted 14 days after its generation.
 
5 Management of App User’s Information
・ Information pertaining to proximity in each App-Installed Device is essentially managed within the App-Installed Device, and is not provided to the exterior from the App-Installed Device.
・ In operating the system(s) for the App, the Ministry of Health, Labour and Welfare takes appropriate information security measures against improper access, viruses, malware, etc., to prevent the occurrence of any problems in ensuring the privacy of App Users. In the event that the system(s) for operating the App are partially contracted to another organization, that organization shall be required to take appropriate information security measures.
・ In operating the system(s) of the App, the Ministry of Health, Labour and Welfare will take appropriate measures for safely managing the data it handles so that App Users are not personally identified as a result of verification against information, managed by the national or local governments, which enables specific individuals to be identified, through system(s), etc. aside from those of the App (including, but not limited to, the Management System) unless in the event it has the explicit consent of the App User described in 3 (3).
 
6 Support Desk and Call Center
・ The Ministry of Health, Labour and Welfare will establish a support desk to receive inquiries and questions relating to the App from the App Users etc. by e-mail and a call center to do the same by telephone.
・ The Ministry of Health, Labour and Welfare will use information, including e-mail address and telephone numbers obtained at the support desk and call center, only to answer inquiries and questions from App Users (this includes use to investigate malfunctions etc. relating to the said inquiries and questions).
 
7 Third Party Provision
・ The Ministry of Health, Labour and Welfare will not provide information obtained by the Ministry of Health, Labour and Welfare via the App and information obtained by the Ministry of Health, Labour and Welfare at the support desk and call center to third parties without the explicit consent of the App User.
 
8 Outsourcing
・ The Ministry of Health, Labour and Welfare may outsource part or all of the operation of the App, support desk and call center (this includes not only direct outsourcing by the Ministry of Health, Labour and Welfare, but also first tier and second tier subcontracting pertaining to the said outsourcing) and the said subcontractor may then handle the information obtained via the App or the information obtained at the support desk or call center. In this case, the Ministry of Health, Labour and Welfare will manage and supervise the said subcontractor so that it takes appropriate safe management measures.
・ The Ministry of Health, Labour and Welfare will give information on the Ministry of Health, Labour and Welfare’s website concerning the contact confirmation application about subcontractors who have a subcontracting relationship with the Ministry of Health, Labour and Welfare and who handle information obtained via the App and information obtained at the support desk or call center.
 
9 Inquiries Regarding Privacy
・ Please contact the Ministry of Health, Labour and Welfare as specified in the App or on the Ministry of Health, Labour and Welfare’s website concerning the contact confirmation application for any questions, etc. regarding privacy in the use of the App.