Update technical-faq.yml #276
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This FAQ addition addresses a common question from Japanese enterprise customers regarding compliance with the Act on the Protection of Personal Information (APPI) in the context of Microsoft Defender for Identity (MDI). Specifically, it clarifies whether end-user consent is required for overseas data transfer when using MDI.
Justification and Accuracy:
The content has been carefully reviewed against official guidance from Japan’s Personal Information Protection Commission (PPC), particularly Q&A 12-3, as well as legal commentaries. According to the PPC and current legal interpretations, providing personal data to Microsoft as part of using MDI is classified as “outsourcing” rather than a “provision to a third party in a foreign country.” Therefore, explicit end-user consent for cross-border data transfer is not required, as long as the proper contractual and supervisory safeguards are in place.
This clarification is important for legal compliance and customer assurance. The FAQ content accurately reflects the current legal requirements and aligns with both Japanese government guidance and Microsoft’s standard contractual obligations.