2020 年 7 巻 p. 78-102
The discussions made in the revision of the Act on the Protection of Personal Information in 2015 revealed the issues that could not be achieved with the amendment, and highlighted that a number of unresolved problems remain in current legislation. One of the issues that could not be achieved is that it was not realized despite being understood that it was necessary to include individual behavioral data recorded with device identiﬁer as the subject of protection under the Act. And the unresolved problem with current legislation is, for example, that the interpretation of the sentence “can be easily matched with other information” in the deﬁnition of personal information has not been clariﬁed. This series of papers attempts to propose a direction to solve the remaining issues for the next revision of the Act. Speciﬁcally, by focusing on the difference between “personal information” and “personal data”, by clarifying the diﬀerence in inter pretation between the sentence “can be easily matched with” and “can be matched with”, we aim to unify only the provision on “personal information ﬁle” in the private sector and the public sector.