If personal information you collected through forms is affected by this incident, you may be required under Japan's Act on the Protection of Personal Information to notify the people who submitted the form (data subjects).
Our October 17, 2026 notice (in Japanese) asked you to hold off only on reporting to the Personal Information Protection Commission. Notifying the people who submitted the form (data subjects) is not included in that request.
When considering whether notification is required, please check the following three points.
① Were you using the form for business or organizational activities?
This includes inquiries, reservations, and job applications. Sole proprietors and nonprofit organizations may also be covered.
Basis: General Rules Guidelines 2-5 “Business operator handling personal information” (in Japanese)
Excerpt (unofficial translation): “a person who uses a personal information database, etc. for business”
② Did the form responses contain “personal data”?
Check whether they contain information that can identify an individual, such as names or contact details, including in free-text fields. If responses containing such information are saved on your Studio.Design dashboard, they are generally considered “personal data,” even if you have not created a separate list yourself.
Basis: General Rules Guidelines 2-4 “Personal information database, etc.” and 2-6 “Personal data” (in Japanese)
Excerpt (unofficial translation): “personal information that makes up a personal information database, etc.”
Reference: Managing Form Responses in the Dashboard
③ Could that information be affected by this incident?
Check the affected projects listed in the individual emails we sent you and the information you collected through your forms. Because there is no minimum number of people for breaches caused by acts with a wrongful purpose, if there is a risk of a breach due to unauthorized access, notification may be required even if only one person is affected.
Basis: General Rules Guidelines 3-5-3-1 (3) “Situations subject to reporting” and 3-5-4-1 “Situations subject to notification and the party obligated to notify” (in Japanese)
Excerpt (unofficial translation): “a situation in which a breach, etc. has occurred or is likely to have occurred”
*Each excerpt is part of the original text of the relevant section. This checklist is for reference only. Please decide for yourself whether notification is required, and what and how to notify, based on the laws, the guidelines, and how you use your forms. Consult a lawyer or other expert as needed.
We have prepared a press release template for businesses that you can use for announcements on your own website and elsewhere. Please edit it to suit the information involved and your situation before use. Note that, separately from an announcement on your website, you may be required to notify the people who submitted the form (data subjects). For details, see General Rules Guidelines 3-5-4 “Notification to the data subject” (in Japanese).
View the press release template (in Japanese)
If you have questions about your affected projects or our notices, or if you would like individual guidance, please contact us through the inquiry form for the unauthorized access.