LINE Corporation's Compliance with Applicable Laws
The privacy laws that apply to LINE are those laws that must be followed in the location where LINE Corporation, the operating company, is located. The Act on the Protection of Personal Information and the Telecommunications Business Act first are representative laws in Japan where our servers, which store user personal information, are located.
The protection of customer information is of the utmost priority to LINE’s management. We employ a much broader definition of personal information than is stipulated by the law. To prevent breaches of communication secrecy, we are particularly strict on protecting the content of messages sent by users.
Act on the Protection of Personal Information―Definition of personal information
In Article 2.1 of the Act on the Protection of Personal Information, the term “personal information” is defined as information about a living individual which can identify the specific individual by name, date of birth or other descriptions contained in such information (including such information as will allow easy reference to other information and will thereby enable the identification of the specific individual).
Consequently, information that does not fit this definition can be deemed as not being “personal information.” For example, a mobile phone number or similar information alone cannot identify a specific person therefore does not qualify as personal information. (A mobile phone number alone cannot single out a specific person.)
However, in certain cases, it is difficult to clearly define whether or not certain data falls within the scope of the legal definition of personal information as stated in the Act on the Protection of Personal Information. In addition, although a person’s name is defined as personal information, it can be said that a name alone cannot identify a specific person since more than one person can have the same first and last name. Moreover, although the Act on the Protection of Personal Information would not apply in cases where a mobile phone number is not deemed to be personal information, it also does not mean that this information should be easily provided to a third party. We believe the negligent handling of such information should be strictly avoided so as not to breach any customer’s privacy.
In light of this, we expanded our definition of personal information beyond the definition in the Act on the Protection of Personal Information. In addition to the personal information we collect from customers, such as mobile phone numbers and email addresses, and the LINE IDs and nicknames created by customers, we also include the internal IDs we use to set up the account within our definition of personal information. In addition to establishing a broader definition for personal information, we also instituted strict internal rules to carefully handle and use this information.
Telecommunications Business Act―Communication secrecy
The message communication service we provide is legally defined as being a telecommunications business. LINE has registered as a telecommunications business with the Ministry of Internal Affairs and Communications, which is the supervising regulatory body in Japan. Consequently, as a telecommunications business, LINE must comply with the Telecommunications Business Act. One of the important principles of this law is the protection of communication secrecy (Article 4). Given that telecommunications is an essential mode of communication in daily human life, the goal of protecting communication secrecy is to ensure the constitutional freedom of thought and expression, and to protect an individual’s privacy (see Explanation of the Telecommunications Business Act by Kazuteru Tagaya (Japanese only)). The term “secrecy” used here refers to facts that are not commonly known and which are deemed to be of considerable benefit to the person as long as the information is not divulged to another party. They are facts that a normal person would aim to keep secret and which would likely be objectively viewed as being a secret (same as above).
The content of the messages sent and received over our LINE app is extremely private information. It goes without saying that a third party should not breach this communication secrecy, but LINE as the communication intermediary should also not break communication secrecy. Given that this principle is called for under Japan’s constitution, we believe that the protection of communication secrecy should be strictly obeyed. In light of its importance, we have established internal rules on protecting communication secrecy to protect the content of communications.