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Privacy Notice

Privacy Notice Template for Indonesia

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Key Requirements PROMPT example:

Privacy Notice

"I need a Privacy Notice for my Indonesian e-commerce startup launching in March 2025, which will collect customer data and use AI-powered recommendation systems, ensuring compliance with the PDP Law while covering international data transfers to our cloud servers in Singapore."

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Document background
This Privacy Notice is essential for organizations operating in Indonesia that collect, process, or control personal data. It is required under Law No. 27 of 2022 (PDP Law) and must be provided to data subjects before or during personal data collection. The document should be used to inform individuals about how their personal data is handled, their rights under Indonesian law, and the organization's data protection practices. The Privacy Notice must address specific requirements outlined in the PDP Law and KOMINFO regulations, including transparency in processing activities, data security measures, and international transfer requirements where applicable. It serves both as a compliance document and as a trust-building tool with stakeholders, demonstrating commitment to data protection principles and regulatory requirements in Indonesia.
Suggested Sections

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

2. Scope of Privacy Notice: Clear description of who the privacy notice applies to and what activities it covers

3. Types of Personal Data Collected: Detailed list and description of personal data categories collected and processed

4. Purposes of Processing: Explanation of why personal data is collected and how it will be used

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

6. Data Sharing and Disclosure: Information about third parties with whom data is shared and the purposes of sharing

7. Data Security Measures: Description of technical and organizational measures to protect personal data

8. Data Subject Rights: Explanation of individual rights under the PDP Law and how to exercise them

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

10. Contact Information: Details for contacting the organization regarding privacy matters

Optional Sections

1. International Data Transfers: Required if personal data is transferred outside of Indonesia, detailing the legal basis and safeguards for such transfers

2. Cookies and Tracking Technologies: Required for online services that use cookies or similar tracking technologies

3. Children's Privacy: Required if services are directed at or may collect data from children under 17 years old

4. Specific Processing Activities: Required for special categories of data processing such as profiling or automated decision-making

5. Industry-Specific Disclosures: Required for regulated industries with additional privacy requirements (e.g., healthcare, financial services)

Suggested Schedules

1. Data Processing Activities Register: Detailed list of specific data processing activities, including purposes, categories of data, and retention periods

2. Technical and Organizational Measures: Detailed description of security measures implemented to protect personal data

3. Third Party Processors List: List of approved data processors and sub-processors, including their roles and locations

4. Cookie List: Detailed list of cookies and similar technologies used, including their purposes and duration (if applicable)

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
Processing
Consent
Data Protection Officer
Privacy Notice
Cookies
Third Party
Data Breach
Cross-border Transfer
Anonymization
Pseudonymization
Electronic System
Electronic System Operator
Regulatory Authority
KOMINFO
Data Protection Impact Assessment
Data Subject Rights
Legitimate Interest
Data Retention
Technical and Organizational Measures
Processing Register
Automated Decision Making
Profiling
Child Data Subject
Data Minimization
Special Categories of Personal Data
Relevant Industries

Technology

Healthcare

Financial Services

E-commerce

Education

Telecommunications

Retail

Insurance

Professional Services

Manufacturing

Hospitality

Transportation

Media and Entertainment

Relevant Teams

Legal

Compliance

Information Technology

Information Security

Risk Management

Data Protection

Operations

Digital Services

Customer Relations

Corporate Governance

Relevant Roles

Chief Privacy Officer

Data Protection Officer

Legal Counsel

Compliance Manager

Information Security Manager

Risk Manager

IT Director

Chief Technology Officer

Chief Information Security Officer

Privacy Manager

General Counsel

Regulatory Compliance Officer

Data Governance Manager

Operations Manager

Digital Services Manager

Industries
Law No. 27 of 2022 on Personal Data Protection (PDP Law): Indonesia's main data protection framework that regulates the collection, processing, storage, and transfer of personal data. It includes requirements for privacy notices, consent mechanisms, and data subject rights.
Government Regulation No. 71 of 2019 on Electronic Systems and Transactions: Provides requirements for electronic system operators, including provisions on data protection and privacy in electronic systems.
KOMINFO Regulation No. 20 of 2016 on Personal Data Protection in Electronic Systems: Specific requirements for protecting personal data in electronic systems, including obligations for privacy notices and consent mechanisms.
Minister of Communication and Information Technology Regulation No. 5 of 2020: Regulates private electronic system operators and includes provisions on data protection and privacy requirements.
Law No. 11 of 2008 on Electronic Information and Transactions (ITE Law): Framework law for electronic transactions and systems that includes basic provisions on data protection and privacy.
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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