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  • Post category:COVID-19

On December 21, 2021, Japan launched its COVID-19 Vaccine Certification App. Created by the Digital Agency and the Ministry of Health, Labour and Welfare, the application, named the “COVID-19 Vaccination Certificate Application”, provides digitised versions of the Vaccine Certification. The development of the app plays out in the context of Japan’s ongoing digital transformation. How does the app work? In what contexts is it used? 

How does the app work?


(Image: a screenshot of the App Store showing the COVID-19 Vaccination Certificate Application)


In order to obtain a digital certificate, you must have a smartphone, the Individual Number Card of the applicant, and a passport if the applicant needs the certificate for international travel. 


The applicants’ inoculation status is recorded in the Vaccination Record System, a cloud infrastructure created by the government. As the status is linked with the Individual Number, you will be asked to scan the Card to verify your identity.


Upon selecting the municipality you were residing at the time of the vaccination, the app verifies the inoculation status in the system and provides you with the digital certificate, which comes with a readable QR code. Once created, the QR code can be displayed and read without connecting to the Internet. 


According to the Digital Agency, the digital certificate comes with the name, date of birth, a record of the inoculation, and the QR code of the applicant. The name and the date of birth can be hidden by choice. 

How is it used?


The digital certificate is intended to be used upon international travel, or upon entering restaurants and other venues within Japan, although for the time being it appears that the certificate is not expected to be used domestically. 


As of January 22, 2022, there is no nationwide policy mandating the domestic usage of the app nor the digital certificate. This may provide an explanation as to how, as of January 16, 2022, less than three million digital certificates have been issued, according to the Digital Agency, amounting to just 2.4% of the population. With just 41% of the population owning an Identification Number Card, more than half of the population do not have the prerequisites of being issued the certificate.


As of January 22, certain restrictions, such as the number of people that could be seated on the same table of a restaurant, could be eased in certified venues if all of the members can prove that they have either been vaccinated or have recently tested negative for an antigen test (called the “vaccine-and-test package”). However, the proof of vaccination does not have to be in a digital format.


Some restaurants and hotels have implemented discounts or other benefits for users with a vaccination certificate, but this again does not have to be in digital form. 


What is the legal status of the information in the digital certificate?


The article has so far revealed that the information provided in the digital certificate are as follows: name, date of birth and a record of the inoculation. What is the status of each of the information with regards to the Amended Act on the Protection of Personal Information of Japan?


Article 2 (1) (i) of the Act states that information “containing a name, date of birth, or other descriptions etc. meaning any and all matters (excluding an individual identification code)” fall under the category “Personal information”, while Article 2 (3) states that “personal information comprising a principal’s race, creed, social status, medical history, criminal record, fact of having suffered damage by a crime, or other descriptions etc.” fall under the category “Special care-required personal information” which are subject to stronger protection.


It is clear that name and date of birth are “Personal information”; what about the record of the inoculation? Does it fall under the “Special care-required personal information” as part of “medical history”?


Although there is no clear directive, it appears that the record of inoculation is not considered to be categorised under the “Special care-required personal information.” It is not a medical history (vaccination is a preventive medical act) nor does it fall under one of the information associated with medical history, namely information on medical diagnosis and medication, result of medical checkups and instructions, disabilities, or genomes, as laid out by the Personal Information Protection Commission of Japan


The Vaccinal Situation in Japan


As of January 22, 2022, vaccines are not obligatory in Japan. Restrictions such as shortening of opening hours or freezing alcohol sales in restaurants apply for everyone, vaccinated or not. Some restrictions may be eased by showing a proof of vaccination, but the same could be attained by showing a negative test result. Some have worded this Japanese policy as a “sensible, ethical approach.” 


Despite this position, 78% of the entire population have already been vaccinated twice, as of January 21, 2022, and ranks amongst one of the most vaccinated countries around the world. Vaccination of children between the ages of 5 to 11 was authorised on January 20, 2022. 


Paper certificates could easily be lost, forgotten or ripped. While the digital vaccine certificate is as of now not a requirement in the country, it could encourage more people to benefit from the vaccine-and-test package.


A propos de Chiaki Arai