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Privacy Policy for the Handling of Employee related Personal Information of Audi Japan K.K.

1. Basic Policy

Audi Japan K.K. (hereinafter referred to as “AJ”) strictly complies with the Act on the Protection of Personal Information and other relevant laws and regulations when handling personal information of employees of AJ. For this purpose and to continuously improve and enhance the protection of personal information, AJ establishes this privacy protection policy (hereinafter referred to as the “Privacy Policy”).

2. Scope of Application

This Privacy Policy applies to the use, including but not limited to the joint handling (共同利用) as described in Section 5 below, of personal information of AJ’s employees, including without limitation, full-time employees, directors, part-time employees, fixed-term employees, trainees, interns (hereinafter referred to as the “Employee(s)”), by AJ.

3. Acquisition of Personal Information

AJ acquires the following personal information directly from its Employees:

(i) the name and surname;
(ii) the business telephone and fax number;
(iii) the working location;
(iv) the current job title, position and department
(v) the business email address;
(vi) salary information;
(vii) any information required to be submitted to AJ pursuant to the rules of employment and/or other internal rules of AJ; and
(viii) any other information related to the Employees and their families as AJ deems necessary for handling personnel affairs and/or other company management issues.

4. Purpose of Use of Personal Information

AJ acquires personal information from its Employees for the following purpose:

(i) Payroll, tax and social security administration;
(ii) Internal talent identification, job application interviews, work finding services, feedback provision, performance evaluation, talent development and support;
(iii) Internal compliance tasks, such as AJ’s whistleblower hotline and internal investigations, business partner due diligence tasks and Human Resources processes to ensure compliance;
(iv) Optimization of Human Resources processes;
(v) Execution of activities and/or procedures pursuant to the rules of employment and/or other internal rules of AJ; and
(vi) Any other similar purposes as AJ deems necessary.

AJ uses personal information within the scope of the purpose of use described above. Within the scope required for the achievement of this purpose, AJ may also transfer the above described information acquired from its Employees to its parent company Audi AG in Germany and Audi AG’s group companies as described in Section 5 below. Furthermore, AJ may record personal information included in the content of a transaction or inquiries among AJ, its Employees, Audi AG and Audi AG’s group companies, which will be used solely for handling the Employees’ request appropriately and promptly.

5. Joint Handling (共同利用)

AJ may provide all or part of the Employees’ personal information that AJ collects as described in Section 3 above to its parent company Audi AG in Germany and Audi AG’s group companies within the purpose of use described in Section 4 above. AJ is responsible for this joint handling of Employees’ personal information.

6. Provision to a Third Party

Unless covered by the Section 5 above, AJ will not provide or disclose Employees’ personal information to any third party, unless AJ has obtained the prior consent of the Employees; provided that, AJ may provide personal information without the Employees’ consent, if it is necessary to comply with the request of Japanese or foreign government authorities, a local public body, or a person commissioned by any of such organizations under the applicable laws and regulations, if AJ outsources the whole or a part of the handling of personal information within the scope necessary to achieve the purpose of use (including outsourcing to a forwarding agency, accountants, tax accountants, and attorneys), or if disclosure is otherwise allowed by law.

7. Outsourcing

AJ may outsource certain business administration to subcontractors, which may be located outside of Japan, for the purpose of the efficient performance of AJ’s business and may commission the whole or a part of the handling of Employees’ personal information in possession of AJ to subcontractors, such as payroll service providers, within the scope required for achieving the purpose of use. In such event, AJ will appoint a subcontractor that meets the standards established by AJ, will conclude an agreement concerning the handling of personal information, and will properly manage and supervise such subcontractor.

8. Request for Disclosure of Personal Information

If an Employee wishes to request AJ to disclose, correct, cease to use, or delete the content of the Employee’s personal information handled by AJ (hereinafter referred to as “Request for Disclosure”), the Employee shall send a Request for Disclosure to the contact address set forth below. The Request for Disclosure is handled after the Employee has been identified by a suitable form of identification.

9. Transfer of Personal Information Outside of Japan and/or the European Economic Area

Unless otherwise stipulated in this Privacy Policy, AJ will not transfer personal information of its Employees to a place outside of Japan and/or the European Economic Area.

10. AJ’s Contact Information

A Request for Disclosure, questions, complaints, and other inquiries concerning an Employee’s personal information shall be sent to the following place of contact:

Address: Audi Japan KK (attn: Compliance Officer)
Gotenyama Trust Tower 16F, 4-7-35 Kita Shinagawa, Shinagawa-ku, Tokyo 140-0001, Japan
E-mail: compliance@audi.co.jp