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Joint Control Addendum

Joint Control Addendum Template for Indonesia

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Key Requirements PROMPT example:

Joint Control Addendum

"I need a Joint Control Addendum under Indonesian law for a partnership between my e-commerce company and a Singapore-based payment processor, with specific focus on cross-border data transfers and compliance with both jurisdictions' requirements, to be effective from March 2025."

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Document background
The Joint Control Addendum is essential when two or more organizations jointly determine the purposes and means of processing personal data under Indonesian law. This document should be used when entities engage in shared data processing activities and need to clearly define their respective roles, responsibilities, and compliance obligations under Indonesia's Personal Data Protection Law (Law No. 27 of 2022). The addendum typically accompanies a main agreement and provides specific provisions for joint control arrangements, including detailed procedures for handling data subject requests, breach notifications, and security measures. It's particularly important given Indonesia's strict data protection requirements and the need for clear accountability in joint processing operations.
Suggested Sections

1. Parties: Identification of the joint controllers entering into the addendum

2. Background: Context of the joint controller relationship and reference to the main agreement

3. Definitions: Key terms used in the addendum, including specific Indonesian law terminology

4. Scope and Purpose: Definition of the joint processing activities covered by the addendum

5. Roles and Responsibilities: Detailed allocation of responsibilities between joint controllers

6. Data Subject Rights Management: Procedures for handling data subject requests and designated points of contact

7. Compliance with PDP Law: Specific measures to ensure compliance with Indonesian data protection requirements

8. Security Measures: Technical and organizational measures for data protection

9. Data Breach Notification: Procedures for handling and reporting data breaches

10. Liability and Indemnification: Allocation of liability between joint controllers

11. Term and Termination: Duration of the joint control arrangement and termination provisions

12. Governing Law and Jurisdiction: Confirmation of Indonesian law application and jurisdiction

Optional Sections

1. Data Transfers: Required when personal data will be transferred outside Indonesia

2. Sector-Specific Compliance: Include when processing involves regulated sectors (e.g., financial services, healthcare)

3. Audit Rights: Optional section detailing mutual audit rights between joint controllers

4. Insurance Requirements: Include when specific insurance coverage is required for data protection

5. Local Representative: Required when any joint controller is not established in Indonesia

6. Sub-processing: Include when joint controllers may engage sub-processors

Suggested Schedules

1. Schedule 1 - Processing Activities: Detailed description of joint processing activities and data categories

2. Schedule 2 - Technical and Organizational Measures: Specific security measures implemented by each joint controller

3. Schedule 3 - Data Subject Rights Procedure: Detailed procedures for handling data subject requests

4. Schedule 4 - Contact Points: Key contacts for each joint controller for various purposes

5. Appendix A - Data Breach Response Plan: Detailed procedures for managing data breaches

6. Appendix B - Compliance Checklist: Checklist ensuring compliance with Indonesian PDP Law requirements

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

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alex.den.21@genieai.co
Relevant legal definitions
Addendum
Agreement
Applicable Law
Business Day
Confidential Information
Consent
Controller
Data Breach
Data Protection Laws
Data Protection Officer
Data Subject
Data Subject Rights
Effective Date
Electronic System
Electronic System Operator
Indonesian PDP Law
Joint Controllers
Joint Processing Activities
Local Representative
Main Agreement
Ministry of Communication and Informatics
Personal Data
Personal Data Processing
Processing Purposes
Processor
Regulatory Authority
Representatives
Security Measures
Sensitive Personal Data
Services
Special Categories of Personal Data
Sub-processor
Technical and Organizational Measures
Term
Third Party
Transfer
Relevant Industries

Financial Services

Healthcare

E-commerce

Technology

Telecommunications

Education

Insurance

Professional Services

Retail

Manufacturing

Transportation and Logistics

Real Estate

Relevant Teams

Legal

Compliance

Information Security

Data Protection

Risk Management

Information Technology

Operations

Privacy

Regulatory Affairs

Contract Management

Relevant Roles

Chief Privacy Officer

Data Protection Officer

Legal Counsel

Compliance Manager

Information Security Manager

Risk Manager

Operations Director

Chief Technology Officer

Privacy Manager

Contracts Manager

Chief Information Security Officer

Chief Legal Officer

Data Protection Manager

Regulatory Compliance Officer

Industries
Law No. 27 of 2022 on Personal Data Protection (PDP Law): Indonesia's primary data protection legislation that regulates the processing of personal data, including provisions for joint controller arrangements and their obligations
Government Regulation No. 71 of 2019: Regulation concerning the Implementation of Electronic Systems and Transactions, which provides requirements for electronic system operators and data processing
Indonesian Civil Code (Kitab Undang-undang Hukum Perdata): Provides the fundamental principles of contract law in Indonesia, including contract formation, validity, and enforcement
MOCI Regulation 20 of 2016: Regulation on Personal Data Protection in Electronic Systems, which provides specific requirements for protecting personal data in electronic systems
Law No. 11 of 2008 as amended by Law No. 19 of 2016: Law on Electronic Information and Transactions, providing the legal framework for electronic transactions and data processing
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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