Indonesia

Comprehensive

Personal 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 Enforcement

Dedicated supervisory body to be established. Kominfo currently oversees implementation.

Data Subject Rights

Fully Addressed

Rights to information, access, correction, deletion, restriction, objection, and portability.

Cross-Border Transfer

Fully Addressed

Transfers to countries with equivalent or adequate protection. Implementing regulations specify criteria.

Breach Notification

Fully Addressed

Must notify authority and affected individuals within 72 hours.

DPO Requirements

Partially Addressed

Required for certain categories of controllers processing at scale.

Children's Data

Fully Addressed

Parental consent required for children. Specific protections as sensitive data.

Penalties & Enforcement

Pending Enforcement

Fines up to 2% of annual revenue. Criminal penalties up to 6 years imprisonment. Enforcement mechanisms being established.

Sector-Specific Rules

Fully Addressed

OJK financial data rules, health ministry regulations, telecom sector requirements.

AI & Automated Decisions

Not Addressed

No specific provisions on automated decisions in the PDP Law.

Data Localisation

Partially Addressed

GR 71/2019 previously required local processing. PDP Law eases some requirements but sector rules remain.

Significant Data Fiduciary

Not Addressed

No direct equivalent concept.

Government Data

Partially Addressed

PDP Law applies to government processing with national security exemptions.