Privacy Notice Template for Indonesia

A Privacy Notice is a fundamental legal document that organizations in Indonesia must provide to individuals when collecting, processing, or controlling their personal data. Under Indonesia's Personal Data Protection Law No. 27 of 2022 (PDP Law), this document serves as your primary tool for ensuring transparency and compliance with national data protection requirements while building trust with your stakeholders.

When do you need this document?

You need a Privacy Notice whenever your organization collects personal data from individuals in Indonesia, whether through websites, mobile applications, customer registration forms, employment processes, or business partnerships. This requirement applies to both Indonesian companies and foreign organizations processing Indonesian residents' data. The notice must be provided before or during data collection, making it essential for e-commerce platforms, financial services, healthcare providers, educational institutions, and any business maintaining customer databases. Additionally, you'll need this document when engaging data processors or transferring personal data internationally, as transparency requirements extend to all processing activities covered under the PDP Law.

Key legal considerations

Your Privacy Notice must include specific elements mandated by Indonesian law, including clear identification of your organization as the data controller, comprehensive descriptions of personal data categories collected, and explicit explanations of processing purposes and legal bases. The document must outline data subjects' rights under the PDP Law, including access, rectification, deletion, and data portability rights, along with procedures for exercising these rights. Security measures, data retention periods, and international transfer arrangements require detailed disclosure. You must also specify contact information for data protection inquiries and include information about your organization's relationship with data processors and third-party service providers. Failure to provide adequate privacy notices can result in administrative sanctions, fines, and reputational damage under KOMINFO enforcement actions.

Legal requirements in Indonesia

Indonesian Privacy Notices must comply with the PDP Law's transparency obligations and KOMINFO regulations, particularly Government Regulation No. 71 of 2019 and KOMINFO Regulation No. 20 of 2016. The document must be written in Bahasa Indonesia for domestic processing activities and be easily accessible to data subjects through your primary communication channels. Specific consent mechanisms must be described when processing sensitive personal data categories, including biometric data, health information, or religious beliefs. For international data transfers, your notice must detail adequacy decisions, appropriate safeguards, or specific authorization procedures required under Indonesian law. Regular updates to your Privacy Notice are mandatory when processing activities change, requiring version control and notification procedures to affected data subjects. Organizations must also ensure their Privacy Notice aligns with sector-specific regulations that may impose additional disclosure requirements beyond the general PDP Law framework.