Indonesia
ComprehensivePersonal Data Protection Law (UU PDP) 2022
Authority: Ministry of Communication and Informatics (Kominfo) | Enforcement: Pending | Enacted: October 2024
Overview
Indonesia enacted its comprehensive PDP Law in October 2022 with a two-year transition period ending October 2024. Modelled on GDPR, it covers consent, data subject rights, cross-border transfers, and establishes significant penalties.
14-Topic Coverage
Data Protection Authority
Pending EnforcementDedicated supervisory body to be established. Kominfo currently oversees implementation.
Consent Requirements
Fully AddressedConsent must be explicit, specific, and informed. Additional lawful bases similar to GDPR.
Data Subject Rights
Fully AddressedRights to information, access, correction, deletion, restriction, objection, and portability.
Cross-Border Transfer
Fully AddressedTransfers to countries with equivalent or adequate protection. Implementing regulations specify criteria.
Breach Notification
Fully AddressedMust notify authority and affected individuals within 72 hours.
DPO Requirements
Partially AddressedRequired for certain categories of controllers processing at scale.
Children's Data
Fully AddressedParental consent required for children. Specific protections as sensitive data.
Penalties & Enforcement
Pending EnforcementFines up to 2% of annual revenue. Criminal penalties up to 6 years imprisonment. Enforcement mechanisms being established.
Sector-Specific Rules
Fully AddressedOJK financial data rules, health ministry regulations, telecom sector requirements.
Cookie/Tracking
Not AddressedNo specific cookie regulation.
AI & Automated Decisions
Not AddressedNo specific provisions on automated decisions in the PDP Law.
Data Localisation
Partially AddressedGR 71/2019 previously required local processing. PDP Law eases some requirements but sector rules remain.
Significant Data Fiduciary
Not AddressedNo direct equivalent concept.
Government Data
Partially AddressedPDP Law applies to government processing with national security exemptions.
Coverage Summary
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