Recording job interviews in Japan: the APPI, the Employment Security Act and the PPC's answers

Recording a job interview you take part in is not a crime in Japan as far as we found, and Japan's privacy regulator says the Act on the Protection of Personal Information (APPI) does not oblige a business to tell the other party that a call is being recorded. What the APPI does require is that you notify or publicly announce the purpose of use, get prior consent before acquiring sensitive personal information, and get consent before sending personal data to a third party abroad, including many US-hosted AI tools. As of October 2026, the practical approach for recruiters is still to tell candidates, ask, and delete recordings once the hiring decision no longer needs them.

This page adds Japan to our country series, which also covers Australia, Canada, Germany and the UK. Quotations from Japanese sources that have no official English version are our translations.

Japan's rules at a glance

Is it legal to record a job interview in Japan?

We found no provision in Japanese law that makes it an offence for a participant to record their own conversation, and no all-party consent rule like those in the Philippines or several Australian states. The Telecommunications Business Act protects communications in transit: Article 4 provides that "the secrecy of communications being handled by a telecommunications carrier must not be infringed" (Article 4, our translation). On its face, that rule protects communications while a carrier handles them; it does not address a participant keeping a record of their own call.

The privacy regulator has answered the recruiter's question directly, though for customer calls. In its APPI Q&A, question 1-10 asks whether a recorded call is personal information and whether a business must tell the other party it is recording. The answer: the content is personal information if it can identify a specific individual, and the business "bears a duty to notify or publish the purpose of use under the Act, but does not bear a duty to tell them that it is recording" (our translation).

So the legal floor in Japan is lower than in most countries in this series. Recruiters should still tell candidates: it costs one sentence, it makes the purpose notice easy to prove, and the same process may include candidates in places where recording without consent is unlawful.

What does the APPI require when you record or transcribe?

• Purpose of use (Articles 17 and 21). Article 21(1) requires a business to "promptly notify the identifiable person of that purpose of use or disclose this to the public" once it has acquired personal information, unless the purpose was already published. Article 21(4)(iv) exempts cases where the purpose "is considered to be clear, in light of the circumstances." Evaluating the candidate may be clear from the circumstances; client sharing, a talent pool or AI model training is not, so say so.
• Sensitive personal information (Article 20(2)). The Act's category of sensitive information covers "race, creed, social status, medical history, criminal record" and other items set by Cabinet Order, and it cannot be acquired without the person's consent in advance. If a candidate volunteers a medical condition on a recorded call, you have acquired it. Steer interviews away from these topics.
• Voiceprints. PPC Q&A 1-11 says that if features extracted from recorded voice are converted into data that a speaker-recognition system can use to authenticate the person, that data is a personal identification code and is personal information on its own. Ask vendors whether they build voice profiles.
• Security (Article 23). Take "the necessary and appropriate measures" to prevent leaks, loss or damage.

What does the Employment Security Act add for recruiters?

Article 5-5 of the Employment Security Act applies to employment placement businesses, employers offering jobs, and anyone "recruiting workers." When they collect, store or use job seekers' personal information, they must do so "within the scope necessary to achieve the purpose of their business," collect it "with that purpose made clear," and store and use it within the scope of that purpose, "except where the person consents or there is another justifiable reason." They must also take the measures needed to manage it properly (our translations). For a recorded interview, that supports a narrow, stated purpose: assessing this application, not building a general profile.

Can candidates see, correct or delete interview recordings?

Article 33 of the APPI lets a person request disclosure of personal data the business holds about them, including in electronic form. A business may withhold all or part where disclosure is "likely to seriously interfere with the proper implementation of the business," which can be relevant to internal evaluations, but the exception is narrow. On correction, PPC Q&A 9-19 says the duty arises only when the content "is not factual," so a business does not have to correct information that is an evaluation rather than a fact.

On deletion, PPC Q&A 9-20 addresses rejected applicants directly. There is no duty to return a résumé, but if a rejected applicant asks the business to stop using their data after "a reasonable period, for handling a re-application and the like," has passed and the business no longer needs it, the business is considered obliged to comply under Article 35(6). Article 22 separately says businesses "must endeavor to ... delete the personal data without delay if they no longer require it." Set a period, write it down and delete on schedule; our retention policy template can help.

Can you send interview recordings to a US vendor or a US hiring manager?

This is where the APPI is stricter than most recruiters expect. Article 28 requires a business, before providing personal data to a third party in a foreign country, to obtain the person's consent in advance, unless the recipient has a system meeting the PPC's standards for equivalent measures, or the country is one the PPC has designated. Before asking for that consent, the business must give the person information about the foreign country's personal information protection system and the recipient's protective measures (Article 28(2)).

PPC Q&A 12-1 confirms that this applies "likewise" when you entrust the handling of personal data to a third party abroad, such as a transcription or AI note-taking vendor, and it names the EU and the UK as the designated jurisdictions (as of its September 2021 update). The United States is not on that list, so for a US-hosted tool you need either the candidate's prior informed consent or a vendor whose system meets the standards. Note one boundary from Q&A 1-42: a recording that mentions a name but is not organized so it can be searched by name is not a "personal information database," and Article 28 applies to personal data in such databases. Transcripts filed by candidate name are.

If you are a foreign business interviewing candidates in Japan, Article 171 applies the APPI to handling the personal information of a person in Japan "in relation to supplying a good or service" to them. A recruiting agency serving job seekers in Japan fits that more clearly than an employer hiring for itself. Your own state's recording law also applies to your end of the call; see two-party consent states.

Using an AI note taker for interviews in Japan

Before choosing a tool, ask where audio and transcripts are processed, whether the vendor keeps audio, whether it builds voice profiles, and whether it trains models on your data. Interview Signal, for example, runs on the interviewer's own computer with no bot in the call, shows a read-aloud consent line with a one-click pause, and sends audio to a speech-to-text provider in short chunks without retaining it; the transcript is still personal data under the APPI. The general questions are in is it legal to use AI note takers in interviews.

A consent line for interviews in Japan

面接を始める前に確認させてください。ご回答を正確に記録し、
選考を適切に行うため、この面接を録音し、文字起こしツールで
記録したいと考えています。記録はこの選考のためだけに使用し、
選考終了後[期間]で削除します。よろしいでしょうか。
お断りいただいても選考に影響はありません。途中で止めることもできます。

(Before we start, may I check something with you? To record your
answers accurately and run the selection properly, I'd like to record
this interview and keep a record with a transcription tool. We use it
only for this selection process and delete it [period] after it ends.
Is that all right? Declining will not affect your application, and we
can stop at any point.)

If the tool sends data abroad, add the Article 28(2) information to your written notice and ask for that consent separately. More wording is in the interview recording consent script.

Checklist before you record interviews in Japan

• Purpose of use published or notified, stating recruitment and any other uses.
• Candidate told about recording and asked, even though the APPI does not require it.
• Questions kept away from sensitive information such as medical history and creed.
• Collection limited to what the recruiting purpose needs (Employment Security Act Art. 5-5).
• For any foreign vendor or affiliate: prior consent with the Article 28(2) information, or a vendor meeting the PPC's standards.
• Voice-profile and model-training questions answered by the vendor.
• Retention period set, with a process for disclosure and stop-use requests.

Interviewing elsewhere in the region? See Singapore, the Philippines, India and New Zealand.