Accenture Health
Insurance Society

The Health Insurance Society conducts its business in accordance with the purpose set forth in the Health Insurance Law.
Purpose:
"The purpose of the Health Insurance Law is to contribute to the stabilization of people's lives and the improvement of their welfare by providing insurance benefits for the illness, injury, or death of workers due to reasons other than work, or childbirth, and for the illness, injury, death, or childbirth of their dependents.

The Health Insurance Law also stipulates that "insurers shall endeavor to provide health education, health counseling, health examinations, and other services necessary for the maintenance and promotion of the health of insured persons and their dependents. This is also stipulated in the law.

In this way, Accenture Health Insurance Society provides medical care for the insured and their families (hereinafter referred to as "subscribers"). Accenture Health Insurance Society not only covers the medical expenses of the insured and their family members for illness and injury, but also subsidizes the expenses of childbirth and death. In addition, if the subscriber temporarily loses income due to illness, injury, or childbirth, Accenture Health Insurance Society will subsidize assistance for living expenses.

In addition, Accenture Health Insurance Society provide health education, health counseling, health examinations, and other necessary services to maintain and improve the health of our subscribers.

The personal information of our subscribers is essential for Accenture Health Insurance Society to conduct our health activity as described above and to provide services to our subscribers.

Accenture Health Insurance Society recognize that the safe storage and handling of this information are our greatest challenge, and Accenture Health Insurance Society will ensure that all our office stuffs and other parties involved in our health activity business are aware of this.

In addition, Accenture Health Insurance Society will always keep in mind the following points and strive to take all possible measures to protect the personal information of subscribers and others.

Accenture Health Insurance Society shall promote the following initiatives from the perspective of appropriately protecting information about individual members (hereinafter referred to as "personal information").

1. Accenture Health Insurance Society will take appropriate security measures to prevent the leakage, loss, damage or unauthorized access to the personal information of its members.
2. Accenture Health Insurance Society will use the personal information provided by our subscribers only for purposes that Accenture Health Insurance Society believes will be beneficial to our subscribers, such as the maintenance and promotion of their health. In addition, personal numbers will be used only for the purposes specified in the scope of use stipulated in the Number Law.
3. Accenture Health Insurance Society will not provide the personal information of our subscribers to any third party, unless Accenture Health Insurance Society has obtained the prior consent of the subscriber. In addition, Accenture Health Insurance Society will not provide personal information that includes a personal number (hereinafter referred to as "specified personal information") to any third party, regardless of whether or not the individual concerned consents.
   However, personal information that is not specified personal information may be provided to a third party without the prior consent of the subscriber in Article 27, Paragraph 1, Items of the "Act on the Protection of Personal Information" (Law No. 57, May 30, 2003)
4. Accenture Health Insurance Society will educate and enlighten its office stuffs on the protection of personal information, and will appoint a manager in each department that handles personal information to ensure the appropriate management of personal information.
5. When Accenture Health Insurance Society outsource the business of Accenture Health Insurance Society, Accenture Health Insurance Society will review and improve it so that Accenture Health Insurance Society can give more consideration to the protection of personal information.
   When entering into a business consignment contract, Accenture Health Insurance Society will thoroughly examine the eligibility of the consignee and ensure that the content of the contract is more protective of personal information.
6. If a subscriber wishes to inquire referral or correct his/her personal information, please contact the office in charge of Accenture Health Insurance Society, and Accenture Health Insurance Society will respond to the request as soon as reasonably possible.
7. Accenture Health Insurance Society will comply with laws, regulations, and other standards related to the handling of subscribers' personal information, and will continuously review and improve the content of this Personal Information Protection Policy.

The Accenture Health Insurance Society (hereinafter referred to as "Accenture Health Insurance Society") has created a personal information database based on the following personal information received from the insured and their families (hereinafter referred to as "subscribers"), and has created the following personal information database. Accenture Health Insurance Society will use it for our health insurance activities.
Personal information described in various notifications, application forms, etc.
Personal information and health examination information described in the "medical fee statement (hereinafter referred to as" receipt ")" requested by the medical institution.
In a larger sense, the purpose of Accenture Health Insurance Society's use of personal information is to "provide insurance benefits related to the illness, injury, or death of subscribers other than work-related accidents or childbirth" as stipulated in the Health Insurance Law, and to "conduct business necessary for the maintenance and promotion of the health of subscribers.
However, Accenture Health Insurance Society handles a lot of medical information, such as receipts and medical checkup data, as well as other personal information, and the business we conduct is one that requires the strong trust of our subscribers.
According to the guidance given by the Ministry of Health, Labor and Welfare, it is advisable that the purpose of the information should be more detailed and limited.
Therefore, Accenture Health Insurance Society will disclose the purpose and method of use of personal information as follows.

1. Purpose of use of personal information

   Types of personal information	Purpose of use
   Information related to eligibility	Subscriber management Determination of monthly standard remuneration Collection of insurance premiums Issuance and management of various certificates Linkage to online eligibility verification system Information linkage based on the number law Confirmation by cross-checking with residential information
   Information on the income of insured persons and dependents	Certification and verification of dependents Issuance and management of elderly beneficiary certificates and standard charge reduction certificates
   Information on the income and status of dependents (including those who wish to become dependents) and their cohabiting family members	Certification and verification of dependents
   Information about the insurer to which the person who lost eligibility has newly joined	Implementation of Receipt Transfer Implementation of coordination between insurers
   Information on cash benefits	Examination and payment of insurance benefits Information linkage based on the number law
   Information on medical receipts	Inspection and payment of insurance benefits, Issuance of medical fee notices, Medical fee analysis for the purpose of subscriber health management and policy planning, Application for high-cost medical subsidies to the National Federation of Health Insurance Societies
   Subscriber account information	Payment of insurance benefits Payment of subsidies Refund of premiums, etc.
   Information on health examinations	Recommendation of medical checkups to those who have not yet received medical checkups Identification of persons eligible for health guidance Analysis of health examination results for the purpose of health management and policy planning for subscribers Recommendation of medical examination for those who need medical treatment Reporting the results of the specified medical checkups to the government Linkage to online eligibility verification system
   Information on health guidance	Recommendation of the use of health guidance Analysis of the results of health guidance for the purpose of health management of subscribers and policy planning Reporting the results of specific health guidance to the government
   Information on health services (various subsidies and incentive point grants)	Management of users Screening and payment of subsidies Screening and granting of incentive points
   Information on the labor status of insured persons	Examination and payment of sickness and injury benefits Examination and payment of maternity allowance
   Information on the status of medical treatment obtained through inquiries to physicians, etc.	Examination and payment of injury and illness benefits Examination and payment of medical treatment expenses
   Information on third-party actions (traffic accidents, etc.)	Claiming compensation against the perpetrator and insurance company
   Information about our Society Committee members	Communication regarding Society Committee and board meetings Conducting election and training
   Information about our health insurance society's employees	Employment management Conducting training Providing employee benefits

   ※In the following cases stipulated in each item of Article 21, Paragraph 4 of the Personal Information Protection Act, we may not notify or publicly announce the purpose of use.

   1. When notifying the individual of the purpose of use or publicly announcing it would be harmful to the life, body, property, or other rights and interests of the individual or a third party.
   2. When notifying the individual of the purpose of use or publicly announcing it would be harmful to the rights or legitimate interests of Accenture Health Insurance Society.
   3. When it is necessary to cooperate with a national institution or local government in carrying out business prescribed by law, and notifying the individual of the purpose of use or publicly announcing it would be harmful to the performance of said business.
   4. When the purpose of use is deemed clear from the circumstances of acquisition.

   ※Accenture Health Insurance Society is commissioned by employers(Accenture Japan) to conduct periodic medical examinations.

   ※For the purpose of maintaining and improving the health of the insured person and early detection of diseases, information on whether or not the insured person has received medical examinations may be provided from medical institution bills (receipts) at the request of the business office in order to facilitate the recommendation of medical examinations such as re-examinations conducted by the employer.

   ※When it is more efficient and effective to outsource the implementation of our health insurance's statutory and peripheral operations and health services, Accenture Health Insurance Society outsource them to external specialized organizations (see below).

   1. Accenture Health Insurance Society outsources the legal and peripheral operations of "Application" "Benefit" to "Value HR Co. (BPO)
   2. Outsourcing of Services Related to Receipts
      • The inspection of receipt data is outsourced to Taisho Audit Co.
      • Based on receipt data, we outsource to contractors "Value HR Corporation and Hoken Corporation" to notify subscribers of the difference in drug costs between generic drugs and brand-name drugs.
      • With regard to claims for medical treatment expenses for judo therapists, Accenture Health Insurance Society entrust an inspection agency (Gulliver International Co., Ltd.) to confirm the date and details of the treatment for the person who received the treatment.
      • In the event that a person receives insurance medical treatment due to the act of a third party, such as a traffic accident, Accenture Health Insurance Society will commission "Taisho Audit Corporation" to investigate, etc., and submit a copy of the receipt of the person concerned to the non-life insurance company as proof of medical expenses.
   3. Health examinations are conducted on consignment by "Value HR Co.
   4. Accenture Health Insurance Society provide receipt data, health checkup data, and application data to IQVIA, Inc and JMDC, Inc. for medical cost analysis.
   5. Health services are outsourced to “Value HR Co.”, “Senmoni Healthcare Network”, “Linkage Inc.
2. Details of safety control measures

   Organizational safety management measures.	Accenture Health Insurance Society will appoint a person responsible for handling personal information. The Society will clarify the staff who will handle personal data and the scope of personal data they will handle. The Society have established a system for emergency contact with the person responsible in the event that we become aware of facts or signs of violations of the law or the Health Insurance Society's regulations. The Society regularly conduct self-inspections of the handling of personal data, and audits are conducted by auditors.
   Personnel safety management measures.	Matters concerning confidentiality of personal data will be stipulated in work regulations of Accenture Health Insurance Society. Regular training will be provided to our society's employees on important points concerning the handling of personal data. The effectiveness of this training will be verified and reflected in measures for protecting personal information.
   Physical safety control measures.	In areas where personal data is handled, the society manages the entry and exit of employees and restrict the devices they can bring in. The society also implements measures to prevent unauthorized persons from viewing personal data. The society takes measures to prevent theft or loss of devices, electronic media, documents, etc. that handle personal data. The society also implements measures to prevent personal data from being easily discovered when such devices, electronic media, etc. are carried, including when moving around the workplace.
   Technical safety control measures.	The society has introduced a mechanism to protect information systems that handle personal data from unauthorized external access and malware. The society is constantly reviewing this mechanism and implementing strict access control for such information systems. The society limits the persons in charge and the scope of personal information databases, etc. that they handle.

3. Procedures for responding to requests for disclosure, etc. of personal data held by Accenture Health Insurance Society.
   In accordance with the guidelines established by Accenture 　Health Insurance Society, the Society will respond to requests for notification of the purpose of use of retained personal data, disclosure, correction, etc. (correction, addition, deletion), or suspension of use, etc. (suspension of use, erasure, suspension of provision to third parties).
   For details, please see the "Procedure to Disclose, Correct and Stop Use of Personal Data" page*.

   *Accenture Health Insurance Society website → Privacy Policy → Procedure to Disclose, Correct and Stop Use of Personal Data.
4. Storage, Disposal, and Deletion

   Personal information of the Society will be stored, managed, disposed of, and deleted as follows.

   1. Paper-based personal information such as various notifications, application documents, receipts, etc. will be stored in the warehouse for the specified storage period in accordance with the document management rules of the Society when the input processing is completed, and will not be taken out of the storage area except when necessary for confirmation, etc.
      Personal information in media other than paper will be stored and managed appropriately in accordance with the operational management rules for storage in media other than paper.
   2. For personal data that has been stored for a specified period of time or that has been processed and is no longer needed, paper documents will be cut to an unreadable size, and large amounts of personal data will be disposed of by a contractor for dissolution.
      Also, when disposing of personal computers and magnetic media, we will use data-erasure software to make the data unreadable, and then entrust a contractor to dispose of the data or return it to the leasing company.
      The personal information held by the Society will be used only for the health insurance business conducted by the Society.
   3. The disposal of documents is entrusted to "Nagata Shigyo Co., Ltd." and “Yamazaki Buneido Co., Ltd."
      Documents are stored in a warehouse managed by Wanbishi Archives, Inc. under contract.
5. Contact for complaints regarding the handling of retained personal data

   Accenture Health Insurance Society
   TEL	03-6380-1601 *Japanese only
   E-mail	kenpo@accenture-kenpo.jp
   Reception time	Weekdays 9:30 to 12:00, 13:00 to 17:00

Anonymous Processed Information" is information about an individual that is processed in such a way that a specific individual cannot be identified. It is information that, if restored, would not re-identify a specific individual.

Accenture Health Insurance Society will continue to create anonymized processed information in the future for our health projects and epidemiological studies.
Files containing anonymized processed information will be provided to Rreceipt analysis vendors using electronic means of communication such as file transfer systems.
The items of information included in the anonymized processed information to be created and provided are: name, gender, date of birth, eligibility information for Accenture Health Insurance Society(insurance card symbol number, user ID (irreversible hashing), enrollment period,withdrawal period, individual/family classification (relationship), etc.), history of medical fee statements (medical, DPC, dental, prescription), Name of physician associated with subscriber, history of medical examinations (date and time of examination, medical examination (date and time of medical examination, data on medical examination items (numerical values, etc.), history of specific health guidance).No personally identifiable information is included.

• JMDC Corporation
• IQVIA Solutions Japan G.K.
• Value HR Co.

Notify the insured of the "medical expense statement and insurance benefit decision notice" and "other decision notice" including the dependents.
Regarding the personal information (personal data) that the health insurance association holds, based on the "Guidance for the proper handling of personal information by the health insurance association, etc." dated April 14, 2017, the following matters "By changing the current notification method such as notification of medical expenses and things that are beneficial to the insured, the burden on the health insurance association is enormous, and it is not always rational for the person to obtain explicit consent. If there is no clear statement of opposition or suspension from the insured, etc., the content that cannot be said to be treated as if comprehensive consent by implied consent has been obtained for the use of such personal information. Can be done. ”, It will be treated as a comprehensive agreement.
In addition, "Medical expense statement and benefit decision notice" and "Other decision notice" are not only related to the insured person but also to the family members, so they are also applicable to the family members.

1. Provision of Personal Information to Third Parties (Comprehensive Permission)

   The contents of the "Notification of Medical Bill Details and Insurance Benefits" defined in "Purposes of Personal Information Use" may be provided to third parties. However, "third parties", as used herein, refers to dependents, from the point of view of insured parties, and insured parties, from the point of view of dependents.

2. Personal Information (Personal Data) Provided to Third Parties and Methods of Provision
   1. Personal Information Provided to Third Parties
      The name of persons who received medical care, the date of care, the cost required for care, co-payments, the name of the medical facility where care was received, the value of cash benefits and other benefits provided by Accenture Health Insurance Society.
   2. Means or method of provision
      Name of the person who received medical treatment, date and time of medical treatment, cost of medical treatment, amount of co-payment, name of the medical institution where the person received medical treatment, amount of cash benefits provided by the health insurance association, amount of additional benefits.
   3. Consent and withholding can be changed at any time upon request from the insured.
3. Procedures to Stop Provision to Third Parties
   1. An insured party who does not agree to items within the purposes of use may require that Accenture Health Insurance Society obtain explicit consent to provide the relevant information.
   2. An insured party will be assumed to have given consent for the indicated purposes of use unless they have expressed their refusal, as noted above.
   3. Consent and suspension of consent may be changed at any time by request of the insured party.
4. To request provision be stopped, please call the following number.

   Accenture Health Insurance Society
   TEL	03-6380-1601 *Japanese only
   E-mail	kenpo@accenture-kenpo.jp
   Reception time	Weekdays 9:30 to 12:00, 13:00 to 17:00

Under the Personal Information Protection Law, the consent of the individual is required in principle when personal information is provided to a third party.
However, (1) provision to a entrust company, (2) provision in connection with a merger, etc., and (3) joint use by a group - are not considered provision to a third party under the law. Accenture Health Insurance Society shares medical fee statement data in order to receive subsidies for medical expenses from the High Cost Medical Subsidy Program conducted by Federation of Health Insurance Associations in the event that high medical expenses are incurred.
Therefore, as required by law, we will publicly announce (1) the joint use, (2) the personal data items to be jointly used, (3) the scope of the joint users, (4) the purpose of use of the joint users, and (5) the name or names of the personal data manager, as follows.

1. Joint Implementation of High-Cost Medical Care Program with the Federation of Health Insurance Associations

   Health Insurance Societies and Federation of Health Insurance Associations have implemented a program based on Article 2 of the Supplementary Provisions of the Health Insurance Law, under which Federation of Health Insurance Associations grants a portion of the cost of high medical expenses incurred by Societies.
   In order to apply for this program, Societies submit (1) a medical fee statement (dispensing fee statement) with CSV information of the electronic receipt or a copy of the paper receipt, and (2) the "Grant Application Summary Statement Data" which records (describes) the name of the patient, gender, family members, inpatient and outpatient status, year of treatment, and amount billed for the receipt or Grant Application Summary Statement submit to the Health Insurance Federation of Japan, Grant Program Group, High-Cost Medical Care Section. Accenture Society’s high medical expenses are reduced by receiving this grant.

2. Personal Data Items to be Shared

   "Grant application summary statement data" and "Grant application summary statement" and all items in the Receipt data.

3. Scope of Parties Sharing Receipt Data

   • Accenture Health Insurance Society
     -Person in charge of handling personal information:
     Managing manager, Office Manager, Person in charge of benefits

   • Health Insurance Federation Grant Program Group
     -Staff in charge of high-cost medical care (updated version as of March 2022)

   • Outsourcing partner
     -Public Interest Incorporated Foundation Japan Productivity Center ICT
     Healthcare Promotion Department and Cooperating company

4. Purpose of use of persons with whom receipt data is shared

   Accenture Society uses the receipt data to apply for the high-cost medical care program and to receive a portion of the medical care grant.
   In order to accept applications from all Societies, Health Insurance Federation, Grant Program Group, High-Cost Medical Care Section use the receipt data to check that the applications from such Societies are correct and to ensure that they are properly granted. In addition, receipts that are particularly expensive, amounting to 10 million yen or more per month, are made public, excluding personal information and the amounts and names of the main illnesses, which are used as material for informing the trend of high medical costs.

5. Name and address of the person responsible for management of receipt data, etc., and name of the representative of the corporation

   • Accenture Health Insurance Association
     Address: Value HR Building, 5-21-14 Sendagaya, Shibuya-ku, Tokyo
     -Chairman: Machi Yoshikawa
     -Person responsible for management: Managing manager

   • Federation of Health Insurance Associations
     Address:1-24-4 Minami-Aoyama, Minato-ku, Tokyo
     -Chairman: Shunichi Miyanaga -Person responsible for management: Administrative Manager of Union Support Dept.

6. Questions Regarding Joint-Use of Personal Information

   Accenture Health Insurance Society
   TEL	03-6380-1601 *Japanese only
   E-mail	kenpo@accenture-kenpo.jp
   Reception time	Weekdays 9:30 to 12:00, 13:00 to 17:00

1. Purpose of joint use of personal data

   Accenture Health Insurance Society and the Company jointly use the results of health examinations and other data to help promote the health of employees.
   Of the results of health examinations conducted by Accenture Health Insurance Society, the company provides the legally required health examination items to the Society, and the company bears the cost of the legally required health examinations.
   With the consent of the employee at the time of the examination, Accenture health insurance society also provides the company with the results of medical examinations other than the statutory medical examination items in order to control lifestyle-related diseases over the medium to long term and to provide appropriate health guidance and other follow-up services to those have a risk.
   In addition, information on employees who have not yet undergone medical examinations and information on those who have undergone re-examinations after medical examinations are provided to the company and used to remind employees to undergo medical examinations.（Only whether or not you have had a physician visit in the receipt information）

2. Jointly-Used Personal Information (Personal Data)

   Basic information	Employee number, name, date of birth, gender, affiliation, date of medical checkup
   Legal medical checkup and interview	Body measurement, vision and hearing, urinalysis, blood pressure, auscultation, electrocardiogram, blood test Liver function test, kidney function test, blood lipid test, blood glucose test, chest X-ray test Interview items, health guidance, etc
   Human health checkup, etc.	Chest CT examination, gastric X-ray/endoscopy, colonoscopy, gynecological examination, etc.
   Medical checkup information	Information on medical check-ups, information on medical check-ups for those subject to re-examination （Only whether or not you have had a physician visit in the receipt information）

3. Scope of persons handling personal data
   • Accenture Health Insurance Society:
     Health service staff, Office manager, Managing manager
   • Company:
     Person in charge of Health Promotion Office staff, Health nurses, Industrial physicians
4. Name or title of the person responsible for data management
   • Accenture Health Insurance Society:
     Managing manager (person in charge of handling personal information)
   Company:
   Person in charge of Health Promotion Office
5. Questions regarding this matter

   Accenture Health Insurance Society
   TEL	03-6380-1601 *Japanese only
   E-mail	kenpo@accenture-kenpo.jp
   Reception time	Weekdays 9:30 to 12:00, 13:00 to 17:00

Insured parties requesting Accenture Health Insurance Society disclose, correct or stop use of personal data in its possession should fully complete and submit the stipulated Accenture Health Insurance Society form in accordance with "Handling Guidelines for Personal Data Disclosure/Correction/Cessation of Use".

Obtain a "Request for Personal Data Disclosure", in the case of disclosure, or a "Request for Personal Data Correction/Cessation of Use", in the case of correction/cessation of use, from Accenture Health Insurance Society.
Complete all required areas.
Prepare documents for attachment. Consult with Accenture Health Insurance Society to determine documents that must be attached.
Submit forms and documents to Accenture Health Insurance Society.
For the convenience of persons making requests, Accenture Health Insurance Society work to prevent such procedures from being overly burdensome.
Responses to requests, etc. will be given in writing. In the case of disclosure requests, disclosures will be made without requiring a reason for the request. However, part or all of the information may not be disclosed if such disclosure might risk a third party's property, rights or interests, or significantly interfere with the proper execution of Accenture Health Insurance Society business, or if the personal data for which disclosure was requested does not exist. In such case, the person requesting disclosure will be notified in writing without delay.

Such disclosures will be made in accordance with "Medical Expense Details Disclosure Regulations" and "Handling Guidelines for Medical Expense Details Disclosure". It is difficult for Accenture Health Insurance Society to determine whether the disclosure of medical services billing statements (receipts) would interfere with the requesting party's medical treatment. As such, Accenture Health Insurance Society will consult with the medical facility that issued the relevant receipt as to whether the disclosure of such receipts is appropriate.

As a basic rule, the Society provides disclosure service free-of-charge. However, the Society will bill the requesting party for postage if a response by mail is required. Please contact the Accenture Health Insurance Society with any other concerns or questions you may have.

Accenture Health Insurance Society may consign normal operations to external companies as needed. However, such companies are not considered third parties to whom the provision of personal information is prohibited. In addition to concluding contracts with consignment partners concerning the handling of personal information, the Society also periodically verifies whether their handling of personal information is appropriate.

External consignments to provide medical insurance benefits

• Reviewing medical services billing statements (receipts)
• Medical bill analysis, data input (data entry, image processing)
• Health insurance system-related operations

External consignments to provide health care services

• Data entry of examination appointments, examination results
• Services related to specific health care guidance
• Services related to prevention of serious illness
• Other services related to health guidance
• Services related to medical bill details
• Distribution of health awareness magazines
• Services related to cafeteria plans
• Services related to Mental Health

Personal information shared by Accenture Health Insurance Society and employers

• Jointly-implemented examination results
• Services related to health counseling