Basic Policy on Requests for Information Provision from Investigative Authorities
CCC’s principle is to disclose information from investigative authorities only based on a warrant (“warrant principle”).
However, in exceptional cases where there is recognized urgency and seriousness concerning the protection of life, body, or property, we allow disclosure based on an inquiry letter from investigative authorities. We have defined the criteria for such exceptional handling.
Even when cooperating with inquiry letters, information provided is limited to the minimum necessary. Considering the sensitivity of transaction histories linked to V POINT card usage (such as rental history, purchase history, and V POINT history), such information will not be disclosed.
The specific criteria and organizational framework for this exceptional handling are as follows.
Going forward, we will continuously review the appropriateness of this exceptional handling by accumulating case experience of information provision to investigative authorities and incorporating professional advice from external legal experts as a secondary line of defense.
Criteria for Exceptional Handling
Exceptional handling and provision of information to investigative authorities may be conducted only when there is both “seriousness”*¹ and “urgency” recognized concerning the protection of life, body, or property in the following cases.
（1）Conditions Recognized as “Seriousness” Concerning the Protection of Life, Body, or Property
Crimes Affecting Life or Body
Murder, robbery, kidnapping (including forcible confinement), arson, non-consensual sexual intercourse, violations of laws regulating stalking and related acts, violations of explosives control laws, violations of laws related to the use of incendiary bottles (Molotov cocktails), terrorism, drug-related and organized drug and firearm crimes, loss or disappearance of highly lethal items, assistance for injured persons, suicide threats.
Crimes Affecting Property
Organized fraud (multiple offenders), cybercrime
*¹ From December 1, 2023, the term “urgency/public interest” has been changed to “seriousness” for clarity; however, there is no change in the specific criteria for judgment.
*² Due to the amendment of the Penal Code on July 13, 2023, “forcible sexual intercourse, etc.” has been changed to “non-consensual sexual intercourse, etc.,” and “forcible obscenity” has been changed to “non-consensual obscenity.”
（2） In addition to (1) above, if any of the following conditions of “urgency” are met:
- Within three days of the occurrence of the incident (or the date of a threat of the offense is within three days), and the suspect has not been apprehended (or the suspect’s detention period is due to expire within three days)
- The subject is unconscious and in a life-threatening condition (or the possibility cannot be ruled out)
- The targeted information is at risk of being lost within three days
- It has been demonstrated that there is no time to obtain a warrant and that it is difficult to adopt alternative measures
Organizational Framework for Exceptional Handling
| First Line | Department responsible for formal review. |
|---|---|
| Second Line | Department responsible for content review and for consulting external experts when cases that do not meet the criteria are brought in and require difficult judgment.(The external expert is Attorney Kei Yamamuro (Special Advisor, Uryu & Itoga Law Office; former judge), who has no advisory relationship with CCC.) |
| Third Line | A committee composed of a majority of external experts (including attorneys with extensive judicial experience, different from the external lawyer in the second line) who monitor whether the framework and criteria are properly operated and whether exceptional handling is appropriately conducted within the scope defined by the basic policy.(Name: Information Disclosure Monitoring Committee) |
This policy was formulated based on a report from an advisory committee of external experts convened by CCC in 2019.
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