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Data Protection Impact Assessment Policy

Data Protection Impact Assessment Policy Template for Indonesia

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Data Protection Impact Assessment Policy

"I need a Data Protection Impact Assessment Policy for my Indonesian fintech startup that's planning to launch new AI-powered credit scoring services by March 2025, with specific focus on automated decision-making and cross-border data transfers to Singapore."

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Document background
This Data Protection Impact Assessment Policy is essential for organizations operating in Indonesia that process personal data and need to comply with Law No. 27 of 2022 on Personal Data Protection (PDP Law). The policy becomes particularly crucial when organizations undertake new projects or modify existing processes involving personal data processing. It provides a structured approach to identifying, assessing, and mitigating privacy risks in compliance with Indonesian regulatory requirements. The document includes comprehensive guidance on conducting DPIAs, templates for assessment documentation, and clear procedures for review and approval processes. This policy helps organizations demonstrate compliance with Indonesian data protection regulations while promoting privacy-by-design principles in their operations.
Suggested Sections

1. Purpose and Scope: Defines the objectives of the DPIA policy and its application scope within the organization

2. Legal Framework and Compliance Requirements: Overview of relevant Indonesian data protection laws and regulations that the DPIA must address

3. Definitions and Terminology: Clear definitions of key terms used throughout the policy, aligned with Indonesian PDP Law definitions

4. Roles and Responsibilities: Detailed description of roles involved in the DPIA process, including Data Protection Officer, IT security, legal team, and business units

5. DPIA Trigger Conditions: Specific circumstances and thresholds that require conducting a DPIA

6. DPIA Assessment Methodology: Step-by-step process for conducting DPIAs, including risk assessment criteria and evaluation methods

7. Documentation Requirements: Required documentation and record-keeping procedures for DPIA processes

8. Review and Approval Process: Procedures for reviewing, approving, and signing off on completed DPIAs

9. Monitoring and Regular Review: Requirements for ongoing monitoring and periodic review of existing DPIAs

Optional Sections

1. Industry-Specific Requirements: Additional requirements for specific sectors (e.g., financial services, healthcare) - include when organization operates in regulated industries

2. Cross-Border Data Transfers: Specific DPIA requirements for international data transfers - include when organization transfers data outside Indonesia

3. Emergency DPIA Procedures: Expedited DPIA procedures for urgent projects - include for organizations with rapid deployment needs

4. Technology-Specific Assessments: Specific requirements for emerging technologies (AI, IoT, etc.) - include when organization uses advanced technologies

5. Vendor and Third-Party Assessments: DPIA requirements for vendor and third-party relationships - include when organization heavily relies on external processors

Suggested Schedules

1. DPIA Template: Standard template for conducting DPIAs, including all required sections and assessment criteria

2. Risk Assessment Matrix: Template for evaluating and scoring privacy risks, including risk categories and mitigation measures

3. Compliance Checklist: Checklist ensuring alignment with Indonesian PDP Law requirements

4. Data Flow Mapping Template: Template for documenting personal data flows within processing activities

5. Stakeholder Consultation Form: Template for recording stakeholder inputs and concerns during DPIA process

6. DPIA Review Log: Template for tracking DPIA reviews, updates, and approvals

7. Mitigation Measure Implementation Plan: Template for documenting and tracking implementation of risk mitigation measures

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Linkedin in social icon imageX social icon image
alex.den.21@genieai.co
Relevant legal definitions
Personal Data
Special Category Personal Data
Data Protection Impact Assessment (DPIA)
Data Controller
Data Processor
Data Subject
Data Protection Officer (DPO)
Processing
High-Risk Processing
Privacy by Design
Privacy by Default
Risk Assessment
Mitigation Measures
Data Protection Authority
Cross-Border Data Transfer
Data Flow Mapping
Consent
Data Breach
Electronic System
Electronic System Operator
Privacy Risk
Residual Risk
Processing Activity
Data Protection Laws
PDP Law
Data Minimization
Purpose Limitation
Data Subject Rights
Privacy Notice
Data Retention
Technical Measures
Organizational Measures
Impact Assessment
Risk Treatment
Stakeholder Consultation
Prior Consultation
Data Protection Principles
Privacy Impact
Processing Register
Data Protection Framework
Third Party
Clauses
Scope and Application
Legal Basis
Governance
Roles and Responsibilities
Risk Assessment
Documentation Requirements
Compliance Obligations
Review and Approval
Confidentiality
Data Security
Reporting Requirements
Record Keeping
Training and Awareness
Audit and Monitoring
Enforcement
Amendment Procedures
Emergency Procedures
Third Party Management
Cross-Border Considerations
Breach Response
Consultation Requirements
Implementation Timeline
Quality Assurance
Performance Measurement
Exception Handling
Relevant Industries

Financial Services

Healthcare

E-commerce

Technology

Telecommunications

Education

Manufacturing

Retail

Insurance

Government Services

Professional Services

Transportation and Logistics

Energy and Utilities

Media and Entertainment

Relevant Teams

Legal

Compliance

Information Technology

Information Security

Risk Management

Data Protection

Internal Audit

Project Management Office

Human Resources

Operations

Research and Development

Relevant Roles

Data Protection Officer

Chief Privacy Officer

Chief Information Security Officer

Privacy Manager

Compliance Officer

Risk Manager

IT Security Manager

Legal Counsel

Project Manager

System Administrator

Business Analyst

Information Security Analyst

Privacy Analyst

Compliance Analyst

Data Protection Specialist

Industries
Law No. 27 of 2022 on Personal Data Protection (PDP Law): Indonesia's primary data protection legislation that establishes the framework for personal data processing, including requirements for data protection impact assessments
Government Regulation No. 71 of 2019 on Electronic Systems and Transactions: Regulates the implementation of electronic systems and transactions, including security measures and data processing requirements
KOMINFO Regulation No. 20 of 2016: Regulation on Personal Data Protection in Electronic Systems that provides specific guidelines for protecting personal data in electronic systems
Minister of Communication and Information Technology Regulation No. 4 of 2016: Guidelines for the Protection of Strategic Electronic Data, including requirements for risk assessment and management
Law No. 11 of 2008 on Electronic Information and Transactions (ITE Law): Foundational law governing electronic transactions and information, including provisions related to data security
Bank Indonesia Regulation No. 23/6/PBI/2021: Specific requirements for payment system providers regarding data protection and risk assessment in the financial sector
OJK Regulation No. 13/POJK.02/2018: Financial services sector regulation that includes requirements for digital innovation risk assessment and data protection
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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