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Privacy Policy Notice

Privacy Policy Notice Template for Indonesia

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Key Requirements PROMPT example:

Privacy Policy Notice

"I need a Privacy Policy Notice for my Indonesian e-commerce startup launching in March 2025, which will process customer payment data and ship products internationally; the policy must comply with Indonesian PDP Law and include specific sections on cross-border data transfers."

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Document background
A Privacy Policy Notice is a mandatory legal document for organizations operating in Indonesia that collect, process, or store personal data. This document must comply with the Personal Data Protection Law (PDP Law) of 2022 and related regulations, including Government Regulation No. 71 of 2019 and various sector-specific requirements. The notice should be implemented when an organization begins collecting personal data and must be regularly updated to reflect changes in data processing activities or regulatory requirements. It serves multiple purposes: ensuring legal compliance, building trust with stakeholders, and providing transparent information about data handling practices. The document must address specific Indonesian requirements regarding consent, data subject rights, cross-border transfers, and security measures while being accessible to the average reader.
Suggested Sections

1. Introduction: Overview of the policy scope and purpose, including the identity and contact details of the data controller

2. Definitions: Key terms used throughout the policy, aligned with Indonesian PDP Law definitions

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

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

5. Purposes of Processing: Detailed description of how and why personal data is collected and used

6. Data Subject Rights: Explanation of individual rights under Indonesian law, including access, correction, deletion, and data portability

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

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

9. Third-Party Sharing: Details about when and how personal data is shared with third parties

10. Cross-Border Data Transfer: Information about international data transfers and safeguards in place

11. Contact Information: How to contact the organization regarding privacy concerns or to exercise rights

12. Policy Updates: Process for policy updates and how users will be notified of changes

Optional Sections

1. Cookies and Tracking Technologies: Required if the organization operates websites or apps that use cookies or similar technologies

2. Children's Privacy: Required if services might be accessed by or collect data from children under 17

3. Specific Processing Activities: Detailed information about particular processing activities relevant to specific services or products

4. Financial Data Processing: Required if handling financial information, incorporating Bank Indonesia regulations

5. Marketing Communications: Required if personal data is used for marketing purposes

6. Social Media Integration: Required if services integrate with social media platforms

7. Automated Decision Making: Required if using automated processing or profiling systems

Suggested Schedules

1. Data Processing Activities Register: Detailed list of specific data processing activities and their purposes

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

3. Third-Party Processors List: List of approved data processors and their roles

4. Cookie Categories and Purposes: Detailed categorization of cookies and similar technologies used

5. Data Retention Schedule: Specific retention periods for different categories of personal data

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
Privacy Notice
Data Protection Officer
Third Party
Cross-Border Transfer
Data Breach
Cookies
Log Files
Anonymization
Pseudonymization
Electronic System
Electronic System Provider
Data Subject Rights
Data Retention
Automated Processing
Direct Marketing
Technical and Organizational Measures
Legitimate Interest
Special Category Data
Child Data Subject
Data Transfer Mechanism
Privacy Impact Assessment
Data Processing Agreement
Supervisory Authority
User
Service Provider
Application
Website
Device Information
Usage Data
Account Information
Marketing Communications
Profiling
Data Minimization
Storage Limitation
Clauses
Scope and Application
Data Collection
Data Processing
Consent
Data Subject Rights
Data Security
Data Storage
Data Retention
Data Transfer
Third Party Disclosure
Cross-Border Transfer
Data Breach Notification
Children's Privacy
Cookie Usage
Marketing Communications
Automated Processing
Access Control
Security Measures
Record Keeping
Compliance
Updates and Amendments
Complaints Handling
Contact Information
Governing Law
Regulatory Compliance
Liability
Severability
Indemnification
Dispute Resolution
Relevant Industries

Technology

E-commerce

Healthcare

Financial Services

Education

Retail

Telecommunications

Manufacturing

Professional Services

Hospitality

Transportation

Media and Entertainment

Insurance

Real Estate

Non-profit Organizations

Relevant Teams

Legal

Compliance

Information Technology

Information Security

Risk Management

Human Resources

Customer Service

Marketing

Operations

Data Protection

Privacy

Systems Administration

Relevant Roles

Chief Privacy Officer

Data Protection Officer

Legal Counsel

Compliance Manager

Information Security Manager

Risk Manager

IT Director

Chief Technology Officer

Chief Information Officer

Operations Manager

Customer Service Manager

HR Director

Marketing Director

Systems Administrator

Privacy Analyst

Compliance Officer

Industries
Law No. 27 of 2022 on Personal Data Protection (PDP Law): Indonesia's main comprehensive data protection law that establishes the fundamental principles of personal data processing, rights of data subjects, obligations of data controllers and processors, cross-border data transfer requirements, and enforcement mechanisms
Government Regulation No. 71 of 2019 on the Implementation of Electronic Systems and Transactions: Regulates the implementation of electronic systems and transactions, including requirements for data center location, registration of electronic system operators, and data security measures
Minister of Communication and Informatics Regulation No. 20 of 2016: Specific regulation on personal data protection in electronic systems, detailing requirements for obtaining consent, processing personal data, and maintaining data security
Law No. 11 of 2008 on Electronic Information and Transactions (EIT Law): Framework law governing electronic transactions and information, including provisions related to data privacy and security in electronic systems
Bank Indonesia Regulation No. 22/20/PBI/2020: Specific regulations for financial sector data protection and privacy requirements, relevant if the privacy policy involves financial services or payment systems
Minister of Communication and Informatics Regulation No. 5 of 2020: Regulates private electronic system operators, including requirements for platform providers and personal data protection obligations
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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