Records / Laws and rulings

APPI Article 27: provision of personal data to a third party needs prior consent (Act on the Protection of Personal Information, Art. 27(1) and (5))

Giving personal data to another company needs the person's prior consent unless a listed exception applies. A recipient is not a third party only when it is an entrusted processor working within the purpose of use, a successor to the business, or a joint user named in advance (Art. 27(5)); a US buyer that trains its own model fits none of these (my reading).

Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text

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