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UU PDP
Indonesia's Personal Data Protection Law: consent, data subject rights and breach duties.
Also known as: UU PDP, Indonesian data protection law, UU Pelindungan Data Pribadi
Indonesia’s UU PDP (Personal Data Protection Law) governs how companies collect, use, store and share personal data: lawful bases including consent, rights for data subjects (access, correction, deletion, portability, objection), breach notification duties, and cross-border transfer rules. It applies to electronic system operators (PSE) and effectively every digital business handling Indonesian users’ data.
duties: lawful basis + purpose limitation + security + subject rights + breach response
enforcement: phased in with grace periods — track current effective dates, not headlines
For startups the practical core is small: collect only what you need, get real consent where required, honor deletion/access requests through a real process, secure the data (baseline), and have a breach playbook before the breach. Enterprise customers increasingly demand evidence of all five before signing.
The classic mistakes:
- “We’ll comply later.” Data collected unlawfully cannot be laundered later, and retrofitting consent/deletion into architecture is brutal. Design lawful bases and subject-rights flows from the first schema.
- Consent theater. Pre-ticked boxes and bundled consents fail the law’s validity tests and erode trust. Granular, revocable, documented consent — or another lawful basis used honestly.
- No breach playbook. Discovering notification duties mid-incident, while the clock runs. Write the response plan (who decides, who notifies, templates ready) before you need it.
- Vendor blindness. Processors and sub-processors (analytics, cloud, support tools) handle your users’ data under your responsibility. Contract them properly (DPA) and know where data physically goes.
- Assuming GDPR compliance suffices. Overlapping but distinct regimes — local specifics (institutional roles, sectoral rules, phased timelines) need local advice.
Get local counsel early on bases, rights processes and transfers; keep a living data inventory (what, where, why, how long) as the operational backbone. See privacy policy for the public-facing half.