Data Strategy Briefing — July 17, 2024
Indonesia's two-year transition for the Personal Data Protection Law ends on 17 October 2024, leaving multinational data teams under 90 days to localise storage, appoint representatives, and finalise breach playbooks.
Executive briefing: Law No. 27/2022 on Personal Data Protection (PDP Law) granted controllers and processors a 24-month adaptation period that expires on 17 October 2024. Indonesia's Ministry of Communication and Informatics (Kominfo) has reiterated that administrative sanctions, including data localisation orders and fines up to 2% of annual revenue, will begin once the grace period lapses. Global enterprises processing Indonesian personal data must therefore complete localisation, impact assessments, and incident response upgrades ahead of the October enforcement date.
Key governance checkpoints
- Data localisation. Validate that regulated datasets (especially public service, financial, and critical infrastructure records) reside in Indonesian data centres or approved disaster recovery sites per Kominfo guidance.
- Representative appointments. Designate local representatives for offshore controllers, documenting authority to liaise with Kominfo and the forthcoming Data Protection Authority.
- Consent and lawful basis. Reconcile consent records, contractual clauses, and legitimate interest analyses with PDP Law requirements for explicit purpose specification and retention limits.
Operational priorities
- Impact assessments. Complete risk assessments for high-risk processing (biometrics, profiling, large-scale personal data) and prepare mitigation evidence aligned with Articles 34-36.
- Breach readiness. Ensure notification playbooks can meet the 72-hour reporting window to Kominfo and impacted data subjects, including translation and contact strategies.
- Third-party oversight. Update contracts with Indonesian vendors to enforce PDP Law obligations on data processors, including audit rights and localisation attestations.
Enablement moves
- Run tabletop exercises simulating Kominfo inspections triggered by localisation or breach violations.
- Align Indonesian HR, marketing, and fintech subsidiaries on record-of-processing inventory requirements.
Sources
- Undang-Undang Nomor 27 Tahun 2022 tentang Pelindungan Data Pribadi
- Kominfo press release on PDP Law compliance enforcement
Zeph Tech accelerates Indonesia PDP Law readiness with localisation playbooks, Article 34 risk assessments, and Kominfo-facing evidence kits.