Sanno Park Tower 12F (Reception) and 14F,
11-1, Nagatacho 2-chome, Chiyoda-ku,
Tokyo 100-6114, Japan

Tokyo Metro Ginza Line: G06 Tameike-sanno Station, Exit 7 (directly accessible through the second basement)

Tokyo Metro Nanboku Line: N06 Tameike-sanno Station, Exit 7 (directly accessible through the second basement)

Tokyo Metro Chiyoda Line: C07 Kokkai-gijido-mae Station, Exit 5 (3 minutes’ walk)

Tokyo Metro Marunouchi Line: M14 Kokkai-gijido-mae Station, Exit 5 (10 minutes’ walk through Chiyoda Line platform)

AI (Artificial Intelligence)

Across industries, the adoption of AI—particularly generative AI—is accelerating rapidly. While this trend directly contributes to improved operational efficiency and the creation of new businesses, it also gives rise, as an integrated set of issues, to a range of legal and practical challenges. These include information leakage risks where input data contains personal data or confidential information; infringement of copyrights or trade secrets; questions regarding ownership and allocation of rights in training data and outputs; compliance with vendors’ terms of use and appropriate oversight of subcontractors/service providers; and, in the operational phase, ongoing supervision, logging and auditability, and incident response.
In addition, as illustrated by the EU AI Act and similar regimes, certain jurisdictions impose obligations calibrated to the AI system’s risk classification and the role of the relevant economic operator. Accordingly, for matters involving overseas operations and cross-border elements, a legal review of the end-to-end solution design is indispensable.
Our firm places particular emphasis on practical, implementable rulemaking. We provide end-to-end support, from inventorying use cases and establishing internal governance (including human oversight and transparency) to drafting and revising internal policies and contractual clauses and conducting legality and compliance assessments. From the concept and PoC stages onward, we offer “implementable compliance” that enables organizations to move their AI initiatives forward with confidence.

Achievements

Generative AI / AI Tool Implementation & Operations (Internal deployment; provision of products/services to group companies)

Issues spotting for closed-environment deployment and global roll-out (including feasibility of deployment in China; integration with office productivity solutions; image-generation and other multimodal features), covering relevant regulatory requirements in each jurisdiction.
Compliance validation for AI tool usage, including operation of checklists, involvement of the second line of defense, user precautions / notices, and sector-specific regulatory considerations.
Assessment of whether the service “does not handle personal data” (i.e., analysis under the so-called “cloud exception”), including vendor/subcontractor management and security measures; compliance with the APPI Article 28 cross-border transfer rules; and assessment of appropriate disclaimers and user notices.
Identification and documentation of key compliance considerations for generative AI adoption, primarily focusing on handling of personal data and confidential information, and preparation of internal materials.

Personal Data / Data Utilization & AI (Prompting; summarization and analytics; “entrustment” vs. so-called cloud exception, etc.)

Support for APPI-compliant treatment of personal information in the context of generative AI use.

Advice on interpretation of purposes of use where personal information (personal data) is input for AI-driven summarization/analysis, and on whether updates to privacy policies are required.

Advice on interpretation of AI service terms of use, including risks that input data may be used for training; recommended inquiry/approval procedures; and the level of caution required when inputting confidential information.
Advice on structuring “provision” vs. “entrustment” under APPI for AI service use, including establishment of a standards-compliance framework and the design of vendor oversight.
APPI-specific measures where subcontractors, data storage locations, or data processing locations are outside Japan.

Contracts, Commissioned Development, Outsourcing & AI (Development sites; contractors; sub-outsourcing)

Drafting contractual clauses to substantiate the position that “personal data will not be handled” in connection with AI service use, including provisions on security controls and confidentiality.
Advice on use of generative AI in offshore development, including potential applicability of Japan’s foreign exchange and foreign trade regulations and U.S. export controls (e.g., EAR/ECRA), and preparedness for future regulatory changes.
Advice regarding generative AI use in commissioned development, including whether handling of personal data constitutes entrustment, as well as copyright issues, cost negotiations, and considerations under subcontracting/competition-related rules (e.g., abuse of superior bargaining position).
Guidance on copyright treatment in AI-assisted software development, including explanations to user companies and drafting of relevant contractual clauses.

Internal Guidelines / Policies and Governance

Development and revision of guidelines for safe use of generative AI, including positioning of RAG, restrictions on input data, configuration requirements, and整理/analysis of copyright and safety considerations.
Design of governance processes and check items for generative AI usage (including review workflows and operational controls).
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