MyData Japan has submitted a public comment in response to a request for opinions on the "Order to amend part of the Enforcement Regulations of the Act on Certification Services of Local Government Information Systems Corporations Related to Electronic Signatures, etc."

On February 29th, the MyData Japan Public Policy Committee (chairman: Mori Ryoji) submitted a public comment in response to the “Request for comments on the proposed order to amend part of the Enforcement Regulations of the Act on Certification Services of Local Government Information Systems Corporations Related to Electronic Signatures, etc.”, which was announced on January 26th.

This is in conjunction with the provision of the so-called Digital Agency digital authentication app. This digital authentication app is an OpenID Connect authentication server that uses the My Number card as a means of authentication. It enables identity integration with OpenID Connect using the electronic certificate for user authentication and the card information contained in the My Number card.

While this in itself will be very useful, privacy concerns have also been expressed through the media and elsewhere.

• An example
  • Katsue Nagakura (2024)"My Number Card 'authentication app': privacy risk as national government centralizes management of individual usage"Nikkei Crosstech (2024-02-26)
  • Fujiei, Naohiro (2024)"Digital authentication apps are coming"IdM Laboratory (2024-01-28)

MyData Japan also held a public policy committee meeting on February 20th to discuss this matter. After about a week of drafting, we submitted public comments on February 29th.

Public comments

1. The need for regulation of the government's accumulation of information on citizens' service destinations
2. The need for discipline regarding the appropriateness of the use of data provided and data minimization
3. The need for regulations regarding the method of obtaining consent for provision of information

For more details, please see MyData Japan (CEO: Natsuhiko Sakimura)PagesPlease refer from.

[Reference material]

1. Call for opinions on the proposed order to amend part of the Enforcement Regulations of the Act on the Certification Services of the Local Government Information Systems Agency for Electronic Signatures, etc. https://public-comment.e-gov.go.jp/servlet/Public?CLASSNAME=PCMMSTDETAIL&id=290310311&Mode=0
2. Public comment guidelines https://public-comment.e-gov.go.jp/servlet/PcmFileDownload?seqNo=0000267535
3. Outline of the proposed order to amend the Enforcement Regulations of the Act on the Certification Services of the Local Government Information Systems Agency Regarding Electronic Signatures, etc. https://public-comment.e-gov.go.jp/servlet/PcmFileDownload?seqNo=0000267537
4. Order to amend the Enforcement Regulations of the Act on the Certification Services of the Local Government Information Systems Agency Regarding Electronic Signatures, etc. (Draft) https://public-comment.e-gov.go.jp/servlet/PcmFileDownload?seqNo=0000267536
5. Regulations for Enforcement of the Law Concerning the Certification Services of the Local Government Information Systems Agency Regarding Electronic Signatures, etc. https://elaws.e-gov.go.jp/document?lawid=415M60000008120
6. About digital authenticator apps https://public-comment.e-gov.go.jp/servlet/PcmFileDownload?seqNo=0000267538
7. My Number Card AP https://www.soumu.go.jp/kojinbango_card/03.html