[Personal Information Protection] Resident Registration Number, Is it Okay to Process?
Article posted in 2025-03-26 12:49:14 | VEAT
Law firm Veat recently received an inquiry from a sales company (hereinafter referred to as “the client”) regarding the legality of processing resident registration numbers of the client and those of persons entrusted by the client to sell automobiles. In response, Law firm Veat provided detailed legal advice.
What’s the difference in processing resident registration numbers?
The Personal Information Protection Act consists of provisions to protect personal information of information subjects. Among them, resident registration numbers are important personal information, and their processing requirements are stricter than those of general personal information.
That is, even if the information subject consents to its collection and use, except for cases where the law or other regulations specifically requires or allows the processing of resident registration numbers, the personal information processor cannot process resident registration numbers (reference to Article 1, Paragraph 1, Clause 1 of the Personal Information Protection Act).
Therefore, those who intend to process resident registration numbers must operate their business taking into account these differences.
Legal Regulations Concerning Resident Registration Numbers
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Article 8 (New Registration) ③ When an automobile manufacturer, seller, etc. sells an automobile, it shall immediately transmit the |
According to the Act on Automotive Management, when an automobile manufacturer, seller, etc. sells an automobile, it is obligated to transmit the automobile manufacturing certificate information and apply for new registration. In order to prepare an automobile manufacturing certificate and a new automobile registration application, it is necessary to know the resident registration number of the automobile purchaser.
Law firm Veat considered this point and reviewed whether the processing of the purchaser's resident registration number by an automobile seller or a person entrusted to sell automobiles could be deemed as a case where the law or other regulations specifically requires the processing of resident registration numbers in accordance with the Act on Automotive Management.
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Article 32 (Tax Invoice) ① When a business operator provides goods or services (excluding the provision of goods or services for which Value Added Tax is exempted), he/she shall issue a tax invoice (hereinafter referred to as “tax invoice”) to the recipient with the items indicated in the following paragraphs. 2. ⑥ In cases of consigned sales or sales by agents as prescribed by Presidential Decree, even in Paragraph 1, a tax invoice or electronic tax invoice may be issued or received by the provider of goods or services or the recipient of goods or services, as prescribed by Presidential Decree. Article 69 (Tax Invoice Issuance for Consigned Sales, etc.) ① In the case of consigned sales or sales by agents, the consignee or agent shall attach the registration number of the consignee or agent as indicated in Article 32(6) of the Act when delivering goods. In this case, if the provider of goods or services delivers goods directly, the provider of goods or services shall issue a tax invoice. |
According to the Value Added Tax Act, in the case of consigned sales, the consignee shall issue a tax invoice on behalf of the consignor when delivering goods, and the tax invoice shall include the resident registration number of the recipient.
Based on the contents of these legal regulations, Law firm Veat provided detailed legal advice as to whether the client was the party obligated to issue a tax invoice according to the Value Added Tax Act, and whether processing the individual’s resident registration number was lawful based on the relevant provision if the client was the party obligated to issue a tax invoice.
Resolve Legal Risks of Personal Information Processing with Law firm Veat
As mentioned above, even personal information may have different processing possibilities depending on the legal nature of the information. In particular, there may be cases where it is difficult to determine the legality of the business only by the content of the Personal Information Protection Act, so we recommend that you receive a legal review from a legal expert.
Law firm Veat provides customized legal advice to various companies in the personal information protection field. Therefore, if you have questions about compliance with the Personal Information Protection Act, please feel free to contact [Law firm Veat Personal Information Center]. Law firm Veat will provide legal advice optimized for your specific circumstances.
This case study can also be found on the Law firm Veat blog.
- [Personal Information Protection] Can I process resident registration numbers?
Thank you.
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