Indonesia PDP Law Compliance Guide 2024: What SEA Companies Need to Know

Indonesia's Personal Data Protection Law (Undang-Undang Perlindungan Data Pribadi or UU PDP) officially came into force on October 17, 2024. This landmark legislation affects every organization that processes Indonesian citizens' personal data—whether you're based in Jakarta or Singapore.

What is the Indonesia PDP Law?

The PDP Law is Indonesia's first comprehensive data protection regulation, similar to GDPR in Europe or PDPA in Singapore. It establishes clear rules for:

• Collection, processing, and storage of personal data
• Individual rights (access, correction, deletion)
• Cross-border data transfers
• Breach notification requirements
• Penalties for non-compliance

Who Must Comply?

The PDP Law applies to you if:

• Your company operates in Indonesia
• You process personal data of Indonesian citizens (even if you're based abroad)
• You're a data controller or processor handling Indonesian data

This includes fintech companies, e-commerce platforms, SaaS providers, healthcare apps, and any business collecting customer data.

Key Compliance Requirements

1. Lawful Basis for Processing

You must have one of these legal bases:

• Explicit consent from the data subject
• Contract fulfillment
• Legal obligation
• Vital interests protection
• Public interest
• Legitimate interests (with safeguards)

2. Data Protection Officer (DPO)

Organizations processing large volumes of sensitive data must appoint a DPO responsible for:

• Monitoring compliance
• Conducting data protection impact assessments
• Acting as liaison with regulatory authorities

3. Privacy Notices

You must provide clear, accessible privacy notices that explain:

• What data you collect
• Why you collect it
• How long you retain it
• Who you share it with
• Individual rights

4. Data Security Measures

Implement technical and organizational measures:

• Encryption for data at rest and in transit
• Access controls and authentication
• Regular security audits
• Employee training programs

5. Breach Notification

Report data breaches to the regulator within 72 hours of discovery. Notify affected individuals if the breach poses high risk to their rights.

Timeline and Penalties

Grace Period: Organizations have 2 years from October 2024 (until October 2026) to achieve full compliance.

Penalties for Non-Compliance:

• Criminal penalties: Up to 6 years imprisonment and/or fines up to IDR 6 billion (~$385K USD)
• Administrative fines: Up to 2% of annual revenue

Practical Implementation Steps

Phase 1: Assessment (Months 1-3)

1. Data mapping audit: Identify all personal data you collect, process, and store
2. Gap analysis: Compare current practices against PDP Law requirements
3. Risk assessment: Identify high-risk processing activities

Phase 2: Documentation (Months 4-6)

1. Update privacy policies and consent forms
2. Create data processing records
3. Document security measures
4. Prepare breach response procedures

Phase 3: Technical Implementation (Months 7-18)

1. Implement security controls (encryption, access management)
2. Deploy data subject request workflows
3. Set up breach detection and notification systems
4. Establish cross-border transfer mechanisms

Phase 4: Training & Testing (Months 19-24)

1. Train employees on PDP Law requirements
2. Conduct security testing and audits
3. Run breach response drills
4. Review and update documentation

PDP Law vs. Other Regulations

Requirement	Indonesia PDP	Singapore PDPA	GDPR
Consent Required	Yes (explicit for sensitive data)	Yes	Yes (explicit for sensitive data)
DPO Mandatory	For large processors	No	Yes (certain cases)
Breach Notification	72 hours	3 days	72 hours
Max Fine	IDR 6B or 2% revenue	SGD 1M	€20M or 4% revenue

How Niym Can Help

Achieving PDP Law compliance manually is time-consuming and error-prone. Niym automates:

✅ Data mapping and inventory – Automatically discover and classify personal data
✅ Policy generation – Create PDP Law-compliant privacy notices and consent forms
✅ Evidence collection – Gather and organize compliance documentation
✅ Continuous monitoring – Track compliance status in real-time
✅ Breach management – Automate detection and 72-hour notification workflows

Key Takeaways

1. Start now: Don't wait until the 2026 deadline—compliance takes 12-18 months
2. Data mapping first: You can't protect data you don't know you have
3. Automate where possible: Manual compliance doesn't scale
4. Get expert help: Consider AI-powered compliance platforms to accelerate implementation

Additional Resources

• Official PDP Law Text (Indonesian)
• Ministry of Communication and Informatics Guidelines
• Niym PDP Law Compliance Checklist (Download)

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Need help with PDP Law compliance? Get started with Niym and achieve compliance in weeks, not months.