Operating a business in Indonesia today means operating in an environment where data protection is no longer optional. Since the enactment of Law No. 27 of 2022 on Personal Data Protection (UU PDP)—Indonesia’s first comprehensive privacy law—the landscape has shifted significantly. Every company collecting, storing, analyzing, or transferring personal data must comply with a framework that is becoming more structured and more actively supervised as the national Data Protection Authority (Badan PDP) continues to take shape.
This article unpacks the core data privacy obligations applicable to any business operating in Indonesia—whether local or foreign—and provides a practical, human-readable guide based on the latest regulatory updates, sectoral interpretations, and expert analyses. The goal is to help companies understand what the law requires today, what is still evolving, and how to navigate compliance confidently in 2025 and beyond.
Understanding Indonesia’s Data Privacy Framework
Indonesia’s Personal Data Protection Law (UU PDP) functions similarly to global privacy regimes such as the GDPR, introducing legal definitions, data subject rights, controller–processor distinctions, and strict accountability requirements.
A “Personal Data Controller” refers to a party that determines the purpose and means of processing personal data, while a “Personal Data Processor” acts solely based on the controller’s instructions. This distinction matters because obligations vary depending on the role, but in practice, most businesses—especially those with websites, apps, or customer systems—are considered controllers at least in part.
The law establishes rights for data subjects, including access, correction, deletion, objection, and data portability. Businesses must provide mechanisms for individuals to exercise these rights and respond within reasonable timeframes, which will later be standardized as implementing regulations mature.
Importantly, Indonesia is actively building its dedicated Data Protection Authority, which holds enforcement powers, including imposing administrative sanctions. This signals an era in which compliance will increasingly be monitored rather than encouraged voluntarily.
Core Obligations Every Business Must Meet
Establishing a Lawful Basis for Data Processing
Under UU PDP, businesses must clearly identify and document the legal basis for processing personal data, such as consent, contractual necessity, legal obligations, or legitimate interests. Without a lawful basis, processing becomes unlawful, exposing the business to compliance risks.
Because Indonesian regulators emphasize transparency, companies should ensure privacy notices align with actual data practices. Consent mechanisms should be easy to understand and withdraw, and must be specific—especially for sensitive personal data.
Implementing Robust Security Measures
Security is a non-negotiable requirement. Controllers and processors must apply technical and organizational measures including access controls, encryption, logging, incident monitoring, and employee training.
These safeguards should reflect the sensitivity of data being processed. Companies are expected not only to adopt security measures but also to demonstrate them—documentation and audits are part of accountability.
Appointing a Data Protection Officer (DPO)
Where required, businesses must designate a DPO or responsible data protection personnel. The role includes overseeing compliance, advising management, serving as a point of contact for data subjects, and liaising with regulators.
Even if your business is not formally required to appoint a DPO, regulators and legal analyses recommend at least assigning an internal responsible officer to avoid compliance gaps.
Data Mapping and Record Keeping
Every business must maintain internal records of processing activities—what data is collected, why, where it is stored, who accesses it, and for how long it is retained.
This data inventory becomes the foundation for compliance audits, breach investigations, and responding to consumer rights requests.
Data Breach Notification—A Critical Obligation
One of the most operationally significant obligations under Indonesia’s PDP Law is data breach notification. Businesses must notify both the regulator and affected data subjects when a breach occurs.
While exact timelines are still evolving, sectoral guidance (such as financial and electronic system operator requirements) suggests that notifications must be made quickly—often within 14 calendar days. Because breaches can escalate reputational and regulatory risks, companies should invest in:
- Incident detection and escalation workflows
- Pre-approved communication templates
- A cross-functional crisis response team
Failing to notify does not only breach legal requirements—it undermines trust and can significantly worsen regulatory outcomes.
Cross-Border Data Transfers and Localization Considerations
Indonesia allows cross-border transfers of personal data under specific conditions. Businesses must ensure one of the following applies before sending data abroad:
- The receiving jurisdiction has an adequate level of protection,
- Contractual safeguards are in place,
- The data subject gives explicit consent, or
- Transfers are otherwise permitted under the law.
Regulators are expected to issue formal adequacy lists and more detailed requirements for cross-border data transfer impact assessments.
Additionally, Indonesia maintains localization requirements for certain categories of data deemed “strategic” or regulated in sector-specific rules—for example, some financial, telecommunications, and government-related systems must store data domestically. These rules often arise from sectoral agencies such as OJK, Bank Indonesia, and Kominfo, and must be read in conjunction with UU PDP.
Businesses operating cloud platforms, handling payment data, hosting customer accounts, or processing health data should conduct a localization impact assessment early to avoid costly compliance redesigns later.
Sector-Specific Rules Affecting Data Privacy Compliance
While UU PDP applies across all industries, many sectors have their own regulations to complement or tighten privacy obligations.
Financial institutions must comply with additional requirements set by OJK and Bank Indonesia, especially concerning security controls, incident reporting, and outsourcing. Telecommunications and digital platforms are subject to Kominfo’s Electronic System Operator (PSE) regulations, which require registration and impose their own data-handling rules.
Healthcare providers, insurance companies, and education platforms also face sectoral obligations on storage, transfer, and confidentiality. For businesses operating across multiple sectors—or using third-party processors who operate in regulated segments—it is important to understand how these obligations overlap.
Enforcement, Sanctions, and Why Compliance Matters
The UU PDP framework includes a range of enforcement tools, from administrative sanctions to potential criminal liability in severe cases.
Sanctions may include:
- Written warnings
- Temporary suspension of processing activities
- Monetary fines
- Potential criminal penalties for unauthorized disclosure or misuse
As the national Data Protection Authority solidifies its structure, enforcement is expected to become more frequent and more coordinated. Companies should not assume that the lack of historical enforcement means low risk—the trend in ASEAN is toward stricter supervision and visible regulatory actions to build public trust.
Beyond legal consequences, non-compliance threatens customer relationships and brand integrity. Consumers increasingly expect transparency and control over their data, and privacy performance is becoming a competitive differentiator.
Practical Roadmap for Businesses
Although compliance can appear complex, most businesses begin with foundational steps: conducting a data mapping exercise, reviewing consent flows, redesigning privacy notices, updating contracts with processors, strengthening security controls, and assigning internal data protection roles.
Cross-border transfers, localization assessments, and sector-specific obligations require more specialized attention, but a structured roadmap helps companies achieve compliance in manageable stages.
Frequently Asked Questions (FAQ)
Does the PDP Law apply to foreign companies operating online in Indonesia?
Yes. If your business collects or processes personal data of individuals in Indonesia—whether or not you have a physical presence—you must comply with UU PDP.
Is appointing a DPO mandatory for all companies?
Not always. However, regulators expect organizations processing large-scale or sensitive data to appoint a DPO or equivalent. Even if not mandatory, having a responsible officer reduces compliance risk.
Do all businesses need to apply data localization?
No. Localization applies primarily to strategic datasets or sectors regulated under specific laws. However, companies transferring data abroad must perform assessments and ensure lawful mechanisms.
What happens if my business experiences a data breach?
You must notify the regulator and affected individuals promptly. Delays or non-disclosure may result in administrative penalties. Prepare an incident response plan in advance.
Will enforcement get stricter?
Yes. As Indonesia’s national Data Protection Authority becomes operational, enforcement will increase and compliance will no longer be optional.
Conclusion
Indonesia is rapidly shaping a mature data protection ecosystem, with the Personal Data Protection Law setting the foundation and the national regulator preparing to enforce it. For businesses, this means adopting a proactive approach to privacy: understanding what data you hold, why you process it, how it moves, and who has access to it. Compliance is not merely a box-checking exercise—it is becoming essential for sustaining customer trust, reducing regulatory exposure, and positioning your brand as a responsible participant in a digital-first economy.
By taking early steps to align with Indonesia’s privacy requirements, companies can reduce legal risk while improving operational integrity. The businesses that prioritize privacy today will be far better equipped for the regulatory expectations of tomorrow.
If your business needs guidance on complying with Indonesia’s data privacy obligations—whether conducting a data mapping exercise, drafting policies, assessing cross-border transfers, or preparing for regulatory audits—CPT Corporate can help. Our experts provide structured, end-to-end compliance support tailored to your industry and operational needs.
Reach out today to strengthen your data protection framework before enforcement intensifies.
