This Privacy Statement was updated on 24 November 2023.
Protecting the individual’s privacy is crucial to the future of business. We have created this Privacy Statement to demonstrate the firm commitment of SAP (hereinafter “We”, “SAP”, “Us” or “Our”) to the individual’s right to data protection and privacy. It outlines how We handle information that can be used to directly or indirectly identify an individual (hereinafter “Personal Data”).
Visitor Registration and Identity Management systems (‘VRIM’) at SAP are used to ensure the security of personnel and assets at SAP’s premises.
A. General Information
Who do We mean when we say SAP in this Privacy Statement
The controller of VRIM is:
SAP Japan Co., Ltd.
Mitsui Bussan Bldg. 11-12F (reception: 2F)
1-2-1 Otemachi Chiyoda-ku, Tokyo 100-0004
Concur Japan Ltd.
Mitsui Bussan Bldg. 11-12F (reception: 2F)
1-2-1 Otemachi Chiyoda-ku, Tokyo 100-0004
You can reach SAP Group’s data protection officer any time at privacy@sap.com.
For what purposes does SAP process your Personal Data?
We require your Personal Data in order to ensure an adequate level of safety and security for and at SAP's premises.
SAP may use your Personal Data for the following purposes:
to control access to SAP's premises;
to ensure adequate security for and at SAP's premises;
to ensure the safety of SAP employees and visitors to SAP's premises;
to prevent, deter, and if necessary, investigate unauthorized physical access, including unauthorized access to secure premises and protected rooms, IT infrastructure, or operational information;
to prevent sabotage, theft and material damage; and
to support the rightful and valid requests of public authorities for support in an investigation.
This process allows SAP to provide appropriate access to SAP premises and to ensure the security and safety of all SAP employees, suppliers, visitors, and assets across all global SAP locations. This process supports SAP to comply with relevant duty of care as well as other applicable statutory obligations which may apply in your jurisdiction, including identification verification prior to or during access to any SAP-owned or leased premises.
Although providing Personal Data during VRIM is voluntary, without your Personal Data, SAP cannot provide you with access to SAP premises.
What categories of Personal Data does SAP process?
As a visitor to SAP’s premises, we may collect the following information.
Contact Data
SAP processes the following categories of Personal Data as contact data: first name, last name, email address and telephone number.
Personal Data related to the business relationship with SAP (if appropriate)
SAP processes the following category of Personal Data in the context of established business relationships: company name.
SAP Visitor Identity Data
SAP processes the following categories of Personal Data as Visitor Identity Data: visit location, visit registration date and time, date and time of check-in/check-out, visitor photo, visitor Confidentiality Disclaimer signature, host name(s), visitor type (i.e., Visitor, SAP VIP, Event), visitor sub-type (i.e., Auditor, Business Meeting, Contractor/Vendor, Customer, Event, Government, Job Interview, Personal, Sales Partner, Tenant, Training, VIP, VIP (non-SAP)) and visit reason.
How long does SAP store your Personal Data?
SAP does only store your Personal Data for as long as it is required:
To fulfil SAP’s legitimate purposes as further described in this Privacy Statement, unless you object to SAP’s use of your Personal Data for these purposes.
SAP may retain your Personal Data for additional periods if necessary for compliance with legal obligations to process your Personal Data or if the Personal Data is needed by SAP to assert or defend itself against legal claims. SAP will retain your Personal Data until the end of the relevant retention period or until the claims in question have been settled.
Who are the recipients of your Personal Data?
Your Personal Data will be passed on to the following categories of third parties to process your Personal Data:
Companies within the SAP Group, as this is a global organization with global security obligations
Third-party service providers, including contracted security agencies that are contracted to provide security services at SAP
Law enforcement agencies, insurance companies etc. as appropriate in terms of any corporate criminal or other security investigations
SAP Group entities
As SAP is selling its products and services to its customers only via local business relationships, SAP may transfer your Personal Data to the locally relevant SAP group entity for the purpose and to the extent necessary to conduct a business relationship. Other entities of the SAP Group may also receive or gain access to Personal Data either when rendering group internal services centrally and on behalf of SAP SE and the other SAP group entities or when Personal Data is transferred to them on a respective legal basis. In these cases, these entities may process the Personal Data for the same purposes and under the same conditions as outlined in this Privacy Statement. The current list of SAP Group entities can be found here. If you would like to find out which SAP group entity is responsible for the business relationship with you or your employer, please contact Us at SAP-Physical-Sec-Privacy@sap.com.
What are your data protection rights?
Right to access and correct
You can request from SAP at any time access to information about which Personal Data SAP processes about you and, if necessary, the correction of such Personal Data. Please note, however, that SAP can or will delete your Personal Data only if there is no statutory obligation or prevailing right of SAP to retain it.
Right to revoke consent
Wherever SAP is processing your Personal Data based on your consent, you may at any time withdraw your consent by unsubscribing or giving us respective notice of withdrawal. In case of withdrawal, SAP will not process Personal Data subject to this consent any longer unless legally required to do so. In case SAP is required to retain your Personal Data for legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of Personal Data by SAP up to the point in time of your withdrawal.
How can you exercise your data protection rights?
Please direct any requests to exercise your rights to SAP-Physical-Sec-Privacy@sap.com.
How will SAP verify requests to exercise data protection rights?
SAP will take steps to ensure that it verifies your identity to a reasonable degree of certainty before it will process the data protection right you want to exercise. When feasible, SAP will match Personal Data provided by you in submitting a request to exercise your rights with information already maintained by SAP. This could include matching two or more data points you provide when you submit a request with two or more data points that are already maintained by SAP.
SAP will decline to process requests that are manifestly unfounded, excessive, fraudulent, or are not otherwise required by local law. VRIM, by its nature can include Personal Data related to many individuals which would need to be removed or redacted before any request can be processed. As this process is extremely burdensome, SAP may consider such requests as excessive by default depending on the circumstances and nature of your request.
Can you use SAP’s services if you are a minor?
Children. In general, the VRIM is not directed to users below the age of 16 years, or equivalent minimum age in the relevant jurisdiction. If you are younger than 16 or the equivalent minimum age in the relevant jurisdiction, you cannot register with and use this VRIM.
B. Additional Country and Regional Specific Provisions
Where SAP is subject to privacy requirements in Japan
How does SAP comply with reasonable security practices and procedures?
SAP has implemented technology, security features and strict policy guidelines to safeguard the privacy of users’ Personal Data. SAP has implemented appropriate security controls to protect Personal Data and it has established electronic and administrative safeguards designed to secure the information collected and to prevent unauthorized access to or disclosure of Personal Data.
Global Physical Security within SAP is held to certain security standards and compliance frameworks including ISO 27001, NIST and PCI. This Visitor Registration and Identity Management system aligns with the standards documented therein and will manage the program with ITIL based security procedures including: change management, major incident management, asset management and problem management.
How does SAP justify international data transfers?
As part of a global group of companies operating internationally, SAP has affiliates (the “SAP Group”) and third-party service providers outside of Japan and will transfer your Personal Data to countries outside Japan (subject to your consent, where Personal Information are involved) as part of SAP’s international data processing operations in continuing compliance with Japanese Act on the Protection of Personal Information.
Employees and contractors within appropriate SAP functions are authorized to operate the system and access the information it contains. These team members are located in all regions and follow SAP Global Security (SGS) policies and procedures.
