Handling Personal Information
When Conducting Market ResearchCompliance in Market Research(Pulled from the June 2, 2017 material)

May 2019
Japan Medical Marketing Research Group➢ Please re-educate all JMMRG affiliates who handle healthcarerelated matters.
➢ Do so by using either a lecture format, or by going through theprovided materials in a way that will allow said affiliates tounderstand how to handle personal information.
➢ When all employees agree with the content and have shown athorough understanding in the handling of healthcare-relatedmatters, please have the JMMRG representative provide his/her

name, seal, and the number of participants at the top of attached
Training Report sheet.

Guideline prerequisites when conducting market research◼ Research conducted by market research agencies affiliated with the JMMRG shall be donein accordance with this guideline.

◼ This guideline is intended to inculcate the idea that “Market research is not sales
promotion.” Please check the guideline if you feel the market research to be different fromstandard research.
◼ Conducting research in accordance with this guideline will not impede the primary purposeof the research.
◼ The purpose of this guideline is to clearly distinguish the difference between market
research and promotion in order to avoid present doubts, and to abide by laws such as
those found in the Protection Of Personal Information Act. Tasks concerning personal
information will be particularly thorough, so please think of the law in the narrow sense.
◼ It is essential that the research content not be slanderous, offensive, or excessive.
This guideline is meant to support both pharmaceutical companies and market research
agencies to maintain and develop pharmaceutical market research without creating any
misunderstandings by society.

Considerations of Identifiable Personal Information
・ Qualitative/quantitative research results that could lead to the identificationof individuals will not be provided in the deliverable data (will not be delivered)└ Data that could lead to the identification of individuals such as names, facility names, and
DCF codes, will not be included in the deliverable data (it is allowed within the research,but the data will not be delivered)└ Answers from university hospital/advanced treatment hospital physicians that include dataon their location, job title, or age, will not be included in the deliverable data (it is allowed
within the research, but the data will not be delivered)└ If combining multiple flags could lead to personal identification, those flags will not
be included in the deliverable data (it is allowed within the research, but the data will not
be delivered)└ The deliverables will be tabulated data
└ In principle, KOL surveys should not be conducted within quantitative research.
Please conduct questions about KOLs after consulting the research agency.
e.g. Even if they are a doctor, it is unlawful in most cases to publicly release their namewithout consent, unless they are a public figure
Note: Executive positions (e.g. president, hospital director) are public figures;
medical department heads are private figures

Considerations when Observing (Qual. Research)

・ Receive a signed consent agreement from the research participant (pharmaceutical company)prior to conducting the research.
・ Be very careful as to not let the observer (pharmaceutical company) and MR subject come intocontact.

└ Please make sure that the pharmaceutical company also has a thorough understandingof observer-related issues.
└ Please make it a practice to receive a signed consent form for participation via
Focus Vision.
└ If a respondent (e.g. physician) and a participant (observer) accidentally see each other at
the interview facility, the participant is to be excluded from observing the interview.
└ Participants are forbidden from using media (e.g. internet) to look up physicians or facilities
during the interview.
└ If the participant discloses the search results to another participant, please
immediately have that participant removed from the venue.
└ A participant who knows of the respondent can still participate provided they do notdisclose that information.
└ Hard copies, notices, and other documents containing the name of the research agency, areto be examined. Pharmaceutical companies are also advised to raise awareness of thisinternally. (especially to non-research depts.)

Considerations of Recorded Media Deliverables
・ Visual/audio recordings should generally not be delivered・ If delivering: 1) both must be altered and edited;
2) a consent form specifying the terms of use must be made└ Visual/audio recordings should generally not be delivered.
└ If they need to be delivered, they must be blurred and/or edited└ Visual/audio materials may be viewed at a facility specified by the research
agency. However, these materials may not be ”lent out” to be returned later.
└ Please limit the internal viewing and sharing of delivered DVDs/recordings(only in a closed environment)└ External use of recorded media requires the consent of the MR subject, so pleasereceive confirmation from the research agency.
└ The research agency may require confirmation as to who will hear/see thedeliverables in advance.

Considerations of Recorded Media Deliverables└ In the past, there was an incident where someone other than a research participant
thanked a respondent for participating in an interview; thus, please use extreme caution.
└ If pictures are to be delivered (e.g. office visits or photo researches), anything in thebackground that legibly shows the hospital or physician’s name must be edited out.
└ When conducting research from overseas (global pharmaceutical/medical device/agencies), there must be a guarantee that the recorded media will not bedelivered or provided to a Japanese subsidiary.
└ Confirm whether there is a possibility that information on the physician(regardless of format) could be provided to the MRs of the Japanesesubsidiary.

└ Requests for audio/visual deliverables are very common in research intermediated byadvertisement agencies/consulting firms. It is common to hear, “I got them last time” or“Other agencies will do it for me.”└ Therefore, please do not forget to have the pharmaceutical/medical
device companies be very careful when conducting researchintermediated by advertisement agencies/consulting firms.
└ When creating hypothetical Q&As to be used in interviews, please make sure the originalcontent is altered, and is not used as is.