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Fidempli

Data Protection & Privacy

A privacy programme for the GDPR and Japan's APPI.

One programme that shows how personal data is handled, in Europe and in Japan.

The problem

The GDPR asks organisations not only to comply but to be able to show it (Article 5(2)). That means records of processing, notices, processor contracts, a working process for rights requests and a plan for data breaches, all kept current.

Companies working between Europe and Japan also face Japan's Act on the Protection of Personal Information (APPI). Since the amendments in force from April 2022 it requires certain breaches to be reported to the Personal Information Protection Commission and sets stricter rules for transfers out of Japan. Two sets of rules often end up as two sets of paperwork.

What we do

Privacy Programme (GDPR and APPI)

  1. Gap assessment

    We compare your current practice with the GDPR, the German BDSG and TDDDG and, where you handle personal data from Japan, the APPI, and give you a prioritised list of gaps.

  2. Governance and policies

    We set roles and responsibilities, write or update the privacy policy, retention rules and internal guidelines, and define how privacy decisions are made.

  3. Records of processing

    We build or update your records of processing activities under Article 30 GDPR, with purposes, legal bases, recipients, transfers and retention for each activity.

  4. Notices, consent and contracts

    We review privacy notices, consent and cookie processes, data processing agreements and transfer mechanisms, including transfers between the EU and Japan.

  5. Rights requests and breaches

    We set up processes to answer data subject requests within the GDPR deadline of one month and to assess and report breaches within 72 hours, and align them with APPI reporting duties.

  6. Run and improve

    We train staff, review the programme regularly and keep it current as your business, your vendors and the rules change.

AI automation in this service

  • Automated drafts of records of processing entries from your application and vendor inventory, reviewed by our consultants.
  • Automated intake, identity checks and deadline tracking for data subject requests.
  • Automated reminders for policy reviews, retention deadlines and expiring processor contracts.

What you get

  • GDPR and APPI gap assessment with priorities
  • Records of processing activities
  • Privacy policy, retention rules and internal guidelines
  • Reviewed notices, consent processes and processor agreements
  • Processes for data subject requests and data breaches
  • Privacy roadmap and training plan

Frameworks

  • GDPR
  • BDSG
  • TDDDG
  • APPI (Japan)

In detail

GDPR and German law

  • Accountability (Art. 5(2), 24)
  • Records of processing (Art. 30)
  • Transparency and notices (Art. 12–14)
  • Data subject rights (Art. 15–22)
  • Processors (Art. 28)
  • Breach notification (Art. 33, 34)
  • BDSG and employee data
  • TDDDG for cookies and similar technologies

Japan's APPI

  • Purpose of use and notice
  • Security control measures
  • Reporting of certain breaches to the PPC and notifying individuals
  • Transfers to third parties outside Japan
  • Pseudonymously processed information
  • EU–Japan mutual adequacy

Platform

After the project, the Fidempli platform keeps it running

From December 2026, the Fidempli platform adds the AI part of your privacy programme: every AI system with its purpose, data categories and DPIA, ready to feed your records of processing.

Explore the platform
Evidence pack for an authority request next to the request details and the board posture score
Product preview with example data

Frequently asked questions

Why GDPR and APPI together?

Many of our clients work between Europe and Japan. Both laws ask for clear purposes, security measures, breach handling and transfer rules, so one programme with Japanese specifics added avoids duplicate work.

Can personal data flow between the EU and Japan?

The EU and Japan recognise each other's data protection as adequate since 2019, so personal data can generally flow from the EU to Japan without additional transfer tools, subject to supplementary rules on the Japanese side. Transfers out of Japan to other countries follow the APPI's own rules.

How fast must we answer a data subject request?

Under the GDPR without undue delay and within one month, which can be extended by two further months for complex or numerous requests if you inform the person.

Do you replace our data protection officer?

No. We support the person who holds the role. If you need an external data protection officer, that is a separate service.

Is this legal advice?

We give practical compliance support. For questions that need legal advice in the strict sense, we work with your legal team or external counsel.

More services in this domain

Fidempli provides governance, risk and compliance advisory and works alongside your legal counsel. We do not provide legal advice.

Start with a 30-minute AI risk conversation.

A senior consultant replies within one business day. Or join the 3–5 design partners shaping the platform before launch.