This principle is implemented in Japanese law by Article 20 of the APPI, providing that a PIHBO "shall take necessary and appropriate action for the security control of personal data including preventing the leakage, loss or damage of its handled personal data." The PPC Guidelines explain the measures to be taken, including the methods for the establishment of basic policies, data handling rules and various "control actions" (regarding organisational safety as well as human, physical and technological security) (35). In addition, the PPC Guidelines and a dedicated Notice (Appendix 8 on "Contents of the safety management measures that have to be taken") published by the PPC provide more details on measures concerning security incidents involving, for example, the leakage of personal information, as part of the security management measures to be taken by PIHBOs (36).

Finally, the APPI creates a framework for the participation of sectoral industry organisations in ensuring a high level of compliance (see Chapter IV, Section 4). The role of such accredited personal information protection organisations (40) is to promote the protection of personal information by supporting businesses through their expertise, but also to contribute to the implementation of safeguards, notably by handling individual complaints and helping to solve related conflicts. To that end, they may request participating PIHBOs, if appropriate, to adopt necessary measures (41). Moreover, in case of data breaches or other security incidents PHIBOs shall in principle inform the PPC as well as the data subject (or the public) and take necessary action, including measures to minimise any damage and to prevent any recurrence of similar incidents (42). While those are voluntary schemes, on 10 August 2017 the PPC had listed 44 organisations, with the largest one, Japan Information Processing and Development Center (JIPDEC), alone counting 15 436 participating business operators (43). Accredited schemes include sector associations such as for instance the Japan Securities Dealers Association, the Japan Association of Car Driving Schools or the Association of Marriage Brokers (44).

Third, also within the executive branch the Prefectural Police is subject to independent oversight. That includes in particular the Prefectural Public Safety Commissions established at prefectural level to ensure democratic administration and political neutrality of the police (108). These commissions are composed of members appointed by the Prefectural Governor with the consent of the Prefectural Assembly (from among citizens with no public servant position in the police in the five preceding years) and have a secure term of office (in particular only dismissal for good cause) (109). According to the information received, they are not subject to instructions, and thus can be considered as fully independent (110). As regards the tasks and powers of the Prefectural Public Safety Commissions, pursuant to Article 38(3) in conjunction with Articles 2 and 36(2) of the Police Law they are responsible for "the protection of [the] rights and freedom of an individual". To this effect, they are empowered to “supervise” (111) all investigatory activities of the Prefectural Police, including the collection of personal data. Notably, the commissions "may direct the [P]refectural [P]olice in detail or in a specific individual case of inspection of police personnel's misconduct, if necessary" (112). When the Chief of the Prefectural Police (113) receives such a direction or by him-/herself becomes aware of a possible case of misconduct (including the violation of laws or other neglect of duties), (s)he has to promptly inspect the case and report the inspection result to the Prefectural Public Safety Commission (Article 56(3) of the Police Law). Where the latter considers this necessary, it may also designate one of its members to review the status of implementation. The process continues until the Prefectural Public Safety Commission is satisfied that the incident has been appropriately addressed.