A Privacy Policy Notice is a mandatory legal document for organizations operating in Indonesia that collect, process, or store personal data. This document must comply with the Personal Data Protection Law (PDP Law) of 2022 and related regulations, including Government Regulation No. 71 of 2019 and various sector-specific requirements. The notice should be implemented when an organization begins collecting personal data and must be regularly updated to reflect changes in data processing activities or regulatory requirements. It serves multiple purposes: ensuring legal compliance, building trust with stakeholders, and providing transparent information about data handling practices. The document must address specific Indonesian requirements regarding consent, data subject rights, cross-border transfers, and security measures while being accessible to the average reader.
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1. Introduction: Overview of the policy scope and purpose, including the identity and contact details of the data controller
2. Definitions: Key terms used throughout the policy, aligned with Indonesian PDP Law definitions
3. Types of Personal Data Collected: Comprehensive list of personal data categories collected and processed
4. Legal Basis for Processing: Explanation of the legal grounds for collecting and processing personal data under Indonesian law
5. Purposes of Processing: Detailed description of how and why personal data is collected and used
6. Data Subject Rights: Explanation of individual rights under Indonesian law, including access, correction, deletion, and data portability
7. Data Security Measures: Description of technical and organizational measures to protect personal data
8. Data Retention Period: Information about how long personal data is kept and criteria for determining retention periods
9. Third-Party Sharing: Details about when and how personal data is shared with third parties
10. Cross-Border Data Transfer: Information about international data transfers and safeguards in place
11. Contact Information: How to contact the organization regarding privacy concerns or to exercise rights
12. Policy Updates: Process for policy updates and how users will be notified of changes
1. Cookies and Tracking Technologies: Required if the organization operates websites or apps that use cookies or similar technologies
2. Children's Privacy: Required if services might be accessed by or collect data from children under 17
3. Specific Processing Activities: Detailed information about particular processing activities relevant to specific services or products
4. Financial Data Processing: Required if handling financial information, incorporating Bank Indonesia regulations
5. Marketing Communications: Required if personal data is used for marketing purposes
6. Social Media Integration: Required if services integrate with social media platforms
7. Automated Decision Making: Required if using automated processing or profiling systems
1. Data Processing Activities Register: Detailed list of specific data processing activities and their purposes
2. Technical and Organizational Security Measures: Detailed description of security measures implemented to protect personal data
3. Third-Party Processors List: List of approved data processors and their roles
4. Cookie Categories and Purposes: Detailed categorization of cookies and similar technologies used
5. Data Retention Schedule: Specific retention periods for different categories of personal data
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