Data Protection Impact Assessment Policy Template for Indonesia

When your organization processes personal data in Indonesia, you need a comprehensive Data Protection Impact Assessment Policy to comply with Law No. 27 of 2022 on Personal Data Protection (PDP Law). This policy establishes systematic procedures for evaluating privacy risks before implementing new data processing activities, ensuring your organization meets Indonesian regulatory requirements while protecting individuals' personal data rights.

When do you need this document?

You must implement a DPIA policy when your organization plans to process personal data in ways that may pose high risks to individuals' privacy rights. This includes deploying new technologies like artificial intelligence systems, implementing large-scale surveillance systems, processing sensitive personal data such as health or biometric information, or conducting systematic monitoring of public areas. Indonesian regulations require DPIAs for any processing that involves innovative technologies, affects vulnerable populations, or combines datasets from multiple sources. The policy becomes essential when establishing data sharing partnerships, implementing automated decision-making systems, or processing personal data for purposes significantly different from original collection.

Key legal considerations

Your DPIA policy must address several critical legal requirements under Indonesian law. The policy should establish clear procedures for identifying when a DPIA is mandatory, defining roles and responsibilities for conducting assessments, and ensuring consultation with relevant stakeholders including data subjects when appropriate. Key considerations include demonstrating necessity and proportionality of data processing, implementing privacy-by-design principles, and establishing mechanisms for ongoing monitoring and review. The policy must also address cross-border data transfer implications, as Indonesian law requires specific safeguards when personal data leaves the country. Risk mitigation measures should be clearly documented, with escalation procedures for high-risk scenarios that may require consultation with the Indonesian Data Protection Authority.

Legal requirements in Indonesia

Under Indonesian law, particularly Law No. 27 of 2022 on Personal Data Protection and supporting regulations, organizations must conduct DPIAs for high-risk processing activities. The policy must align with KOMINFO Regulation No. 20 of 2016 regarding personal data protection in electronic systems and Government Regulation No. 71 of 2019 on electronic systems and transactions. Indonesian law requires that DPIAs include assessment of legal basis for processing, evaluation of necessity and proportionality, identification of risks to data subjects, and description of measures to address identified risks. The policy should establish procedures for consulting with the Data Protection Officer, obtaining management approval for high-risk processing, and maintaining documentation for regulatory inspections. Organizations must also ensure the policy addresses local data residency requirements and provides mechanisms for data subject consultation when processing may significantly affect their rights and freedoms.