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External Privacy Notice

External Privacy Notice Template for Indonesia

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Key Requirements PROMPT example:

External Privacy Notice

"I need an External Privacy Notice for my Indonesian e-commerce platform launching in March 2025, which will process customer data across Southeast Asia and needs to comply with Indonesian PDP Law while allowing for cross-border data transfers."

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Document background
An External Privacy Notice is a fundamental document required under Indonesian data protection law, particularly following the enactement of the Personal Data Protection Law (PDP Law) in 2022. This document serves as the primary means of communicating an organization's personal data processing practices to external stakeholders, including customers, users, and business partners. It must be implemented by any organization operating in Indonesia that collects and processes personal data, regardless of their sector or size. The notice should be written in clear, accessible language and must address all key aspects of data processing, including collection purposes, legal bases, data subject rights, security measures, and international transfers. Regular updates may be required to reflect changes in data processing practices or regulatory requirements.
Suggested Sections

1. Introduction: Overview of the privacy notice and its purpose, including the identity and contact details of the data controller

2. Scope and Application: Description of who the privacy notice applies to and what activities it covers

3. Types of Personal Data Collected: Detailed categorization of personal data collected, including mandatory and voluntary data

4. Purposes of Processing: Comprehensive list of purposes for which personal data is collected and processed

5. Legal Basis for Processing: Explanation of the legal grounds under Indonesian law for processing personal data

6. Data Collection Methods: Description of how personal data is collected, including direct and indirect methods

7. Data Subject Rights: Detailed explanation of individual rights under the PDP Law and how to exercise them

8. Data Retention: Information about how long personal data is kept and criteria for determining retention periods

9. Data Security: Description of security measures implemented to protect personal data

10. Data Sharing and Disclosure: Information about third parties with whom data is shared and circumstances of disclosure

11. International Data Transfers: Details about cross-border data transfers and safeguards in place

12. Changes to Privacy Notice: Information about how changes to the privacy notice will be communicated

13. Contact Information: Details for contacting the organization regarding privacy matters, including the Data Protection Officer

Optional Sections

1. Cookie Policy: Detailed information about website cookies and tracking technologies, required if the organization operates websites using cookies

2. Children's Privacy: Specific provisions for processing children's personal data, required if services are offered to or may involve children

3. Specific Industry Requirements: Additional privacy requirements for specific sectors (e.g., financial services, healthcare), required for regulated industries

4. Social Media Integration: Privacy implications of social media features and integrations, required if social media functionality is implemented

5. Mobile App Privacy: Specific privacy provisions for mobile applications, required if the organization offers mobile apps

6. Marketing Communications: Detailed information about marketing communications and opt-out procedures, required if engaging in direct marketing

7. Automated Decision Making: Information about automated decision-making processes and profiling, required if such technologies are used

Suggested Schedules

1. Data Categories Matrix: Detailed breakdown of personal data categories, purposes, and retention periods

2. Third Party Processors List: List of approved third-party data processors and their roles

3. Technical Security Measures: Detailed description of security measures and protocols implemented

4. Data Subject Rights Procedure: Detailed procedures for handling data subject rights requests

5. Consent Forms: Template consent forms for specific data processing activities

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
Sensitive Personal Data
Data Subject
Data Controller
Data Processor
Data Processing
Consent
Data Protection Officer
Privacy Notice
Cookies
Log Files
IP Address
Automated Processing
Cross-border Transfer
Data Breach
Third Party
Anonymization
Pseudonymization
Data Retention
Direct Marketing
Electronic System
Electronic System Provider
Legal Basis
Privacy by Design
Privacy Impact Assessment
Regulatory Authority
Data Subject Rights
Data Protection Measures
Information Security
Profiling
Special Category Data
Child Data Subject
Marketing Communications
Data Minimization
Purpose Limitation
Data Accuracy
Storage Limitation
Integrity and Confidentiality
Accountability
Clauses
Data Collection
Consent
Purpose Limitation
Data Processing
Data Security
Data Subject Rights
Data Retention
Data Transfer
Data Sharing
Cross-Border Transfers
Breach Notification
Children's Privacy
Marketing Communications
Cookie Usage
Information Security
Access Control
Accountability
Compliance
Enforcement
Dispute Resolution
Amendments
Contact Information
Legal Basis
Third-Party Processing
Data Protection Measures
Automated Processing
Record Keeping
Regulatory Compliance
Data Minimization
Transparency
Relevant Industries

Technology

E-commerce

Financial Services

Healthcare

Education

Retail

Telecommunications

Manufacturing

Professional Services

Tourism and Hospitality

Transportation and Logistics

Media and Entertainment

Relevant Teams

Legal

Compliance

Information Technology

Information Security

Risk Management

Marketing

Customer Service

Human Resources

Operations

Data Protection

Privacy

Relevant Roles

Chief Privacy Officer

Data Protection Officer

Chief Legal Officer

Privacy Manager

Compliance Manager

Information Security Manager

Risk Manager

Legal Counsel

IT Director

Chief Technology Officer

Chief Information Security Officer

Marketing Director

Customer Relations Manager

Human Resources Director

Industries
Law No. 27 of 2022 on Personal Data Protection (PDP Law): Indonesia's main data protection legislation that regulates the processing of personal data, including collection, processing, storage, disclosure, and erasure of personal data. It establishes rights of data subjects and obligations of data controllers.
Government Regulation No. 71 of 2019 on Electronic Systems and Transactions: Regulates the implementation of electronic systems and transactions, including requirements for electronic system operators and protection of electronic information containing personal data.
Minister of Communication and Information Technology Regulation No. 20 of 2016: Specifically focuses on personal data protection in electronic systems, including requirements for consent, data processing, and security measures.
Law No. 11 of 2008 on Electronic Information and Transactions (ITE Law): Provides the legal framework for electronic transactions and information, including provisions related to the protection of personal data in electronic systems.
Minister of Communication and Information Technology Regulation No. 5 of 2020: Regulates private electronic system operators, including requirements for registration and data center location.
Bank Indonesia Regulation No. 22/20/PBI/2020: Specific regulation for payment system providers regarding data protection and processing in financial services sector.
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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