Security Breach Notification Policy Template for Indonesia

A Security Breach Notification Policy is a mandatory compliance document that establishes your organization's procedures for identifying, assessing, and reporting data security breaches in Indonesia. Under the Personal Data Protection Law No. 27 of 2022, organizations must have comprehensive breach response frameworks to protect personal data and ensure regulatory compliance.

When do you need this document?

You need this policy if your organization collects, processes, or stores personal data in Indonesia. This includes businesses operating e-commerce platforms, financial institutions, healthcare providers, telecommunications companies, and any organization maintaining customer databases. The policy becomes critical when implementing data protection compliance programs, establishing incident response teams, or preparing for regulatory audits. Organizations subject to sector-specific regulations, such as OJK requirements for financial services, must ensure their policies address both general PDP Law obligations and industry-specific breach notification requirements.

Key legal considerations

Your policy must address several critical legal requirements under Indonesian law. The breach classification system should distinguish between high-risk and standard breaches, as this determines notification timelines and requirements. Include specific procedures for documenting breach circumstances, affected data categories, and potential harm to data subjects. The policy should establish clear roles for your Data Protection Officer, legal counsel, and senior management in breach response decisions. Consider including provisions for coordinating with insurance providers and third-party vendors who may be involved in breach incidents. Ensure your policy addresses cross-border data transfer implications if your organization operates internationally, as breaches affecting Indonesian personal data must comply with local notification requirements regardless of where the breach occurs.

Legal requirements in Indonesia

Indonesian law mandates specific notification timelines and procedures that your policy must incorporate. Under the PDP Law, you must notify the Ministry of Communication and Information Technology within 72 hours of discovering a high-risk breach. For breaches affecting electronic systems, Government Regulation No. 71 of 2019 requires additional notifications to relevant authorities. Your policy should include procedures for notifying the National Cyber and Crypto Agency (BSSN) for cybersecurity incidents affecting critical information infrastructure. Data subjects must be informed without undue delay when breaches pose high risks to their rights and freedoms. The policy must establish documentation requirements, including breach registers, impact assessments, and remedial action records. Financial institutions must also comply with OJK notification requirements, which may have different timelines and reporting formats than general PDP Law obligations.