Data Privacy Notice Template for Indonesia

A Data Privacy Notice is a legally required document under Indonesia's Personal Data Protection Law (Law No. 27 of 2022) that informs individuals about how their personal data is collected, processed, and protected. This essential compliance document must be provided by any organization that handles personal data of Indonesian residents, ensuring transparency and legal compliance with the country's comprehensive data protection framework.

When do you need this document?

You need a Data Privacy Notice whenever your organization collects or processes personal data of Indonesian individuals. This includes when operating websites that collect user information, providing digital services requiring customer registration, conducting employee recruitment and HR management, or engaging in marketing activities that involve personal data collection. E-commerce businesses, healthcare providers, financial institutions, and any company with Indonesian customers or employees must implement this notice. The document is also required when partnering with third-party data processors or transferring data across borders, as mandated by Government Regulation No. 71 of 2019.

Key legal considerations

Your Data Privacy Notice must clearly identify the data controller and specify the legal basis for processing under the PDP Law, such as consent, contract performance, or legitimate interests. The notice must comprehensively list all types of personal data collected, from basic contact information to sensitive data categories like health records or biometric data. You must explain data retention periods, security measures implemented, and circumstances under which data may be shared with third parties or transferred internationally. The document should detail data subject rights including access, rectification, erasure, and data portability, along with clear procedures for exercising these rights. Failure to provide adequate notice can result in significant penalties under Indonesian law.

Legal requirements in Indonesia

Under Indonesian law, your Data Privacy Notice must comply with specific formatting and content requirements established by the Ministry of Communication and Informatics. The notice must be written in Bahasa Indonesia for Indonesian residents and be easily accessible through your website or application. You must obtain explicit consent for sensitive personal data processing and provide separate notices for different processing purposes. The PDP Law requires organizations to appoint a Data Protection Officer for certain types of processing and include their contact information in the notice. Your notice must also address data localization requirements under Government Regulation No. 71 of 2019, explaining how personal data is stored and processed within Indonesian territory. Regular updates are mandatory when processing activities change, and you must maintain records demonstrating compliance with notice requirements for regulatory audits.