Data Strategy Briefing — October 17, 2024

Executive briefing: The 24-month transition period for Indonesia's Personal Data Protection Law (Law No. 27/2022) ended on 17 October 2024. Controllers and processors that handle Indonesian personal data must comply with localisation mandates, appoint data protection officers where required, and notify Kominfo of data incidents within 72 hours or face fines and service suspensions.

Key governance checkpoints

• Compliance validation. Conduct post-transition audits to confirm lawful basis mapping, consent records, and cross-border transfer approvals align with PDP Law Chapters III and IV.
• DPA engagement. Establish contact points with Indonesia's Data Protection Authority (once operational) and maintain documentation for any ongoing remediation plans.
• Incident evidence. Ensure breach registers capture notification timing, mitigation steps, and data subject communication templates that meet Article 46.

Operational priorities

• Monitoring and audits. Implement continuous monitoring over localisation controls, processor compliance, and data retention schedules.
• Training refresh. Deliver PDP Law training to frontline teams, with emphasis on consent withdrawal, children's data, and direct marketing restrictions.
• Regulator response plans. Prepare response kits for Kominfo inspections, including records of processing, DPIA logs, and policy attestations.

Enablement moves

• Leverage shared services to monitor Indonesian legislative updates and subordinate regulations as the authority ramps enforcement.
• Integrate PDP Law controls into enterprise-wide privacy dashboards for executive oversight.

Sources

• Undang-Undang Nomor 27 Tahun 2022 tentang Pelindungan Data Pribadi
• Kominfo enforcement press release

Zeph Tech sustains PDP Law compliance through continuous monitoring, evidence automation, and regulator-ready briefing materials.

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