[Consultation] Review of the legality of providing data including location information and device information, etc.

Law firm Veat conducted a review of the legality of providing data including location information and device information, etc.

A Corp, operating IT•Software development and security services, commissioned Law firm Veat to review the legality of collecting location information and device information, etc. on behalf of its clients in order to provide additional solutions.

Accordingly, Law firm Veat conducted a review focusing on whether the data collected by A Corp – including the age group, gender, terminal model information, OS information, app installation number, etc. – could lead to the identification of a specific individual, and whether it could be re-identified when combined with other information.

If the data falls under the definition of “personal information” as stipulated in the revised Personal Information Protection Act, as A Corp will be acting as a data recipient collecting personal information on behalf of its clients, it must ensure that the clients obtain consent from the personal information subjects and take measures such as providing notices through privacy policies.

Ahead of the implementation of the revised Personal Information Protection Act on August 5, 2020, which revised the definition of “personal information” and allows companies to utilize the data for purposes such as statistical reporting, scientific research, and public interest record retention when combining personal information with additional information so that it is impossible to identify a specific individual, companies are paying attention to the utilization and management of personal information.

Changes in the revised Personal Information Protection Act and the impact it will have on companies, as detailed in here, please refer to Law firm Veat’s legal guide if you have any questions, and contact Law firm Veat if you require legal advice regarding the revised Personal Information Protection Act and the Data 3 Act.

Thank you.

Law firm Veat.