Data Protection in Indonesia

Registration in Indonesia

The PDP Law does not contain a specific obligation to register and / or notify supervisory authorities of the processing of personal data.

However, it is to be noted that there is a general registration obligation with the KOMDIGI for any foreign and / or Indonesian party, who provides, manages, and / or trades goods and / or services through electronic systems and / or over the internet as an electronic system operator, provided that:

  • it provides services in the territory of Indonesia;
  • it conducts business in Indonesia; and / or
  • its electronic system is used and / or offered in the territory of Indonesia.

Such a party (commonly also referred to as a "electronic system operator" or "PSE") would be required to make certain registration with the KOMDIGI before its electronic system is to be used in Indonesia which will be marked by the grant of an electronic system operator registration certificate (Surat Tanda Terdaftar Penyelenggara Sistem Elektronik or commonly abbreviated as "TDPSE").

Such a registration requirement is to ensure the reliability, security and compatibility of the electronic system in processing any personal data stored in it. Certain publication of the PSE’s profile is intended to and / or will be made on a website operated by the relevant authority (KOMDIGI) upon successful registration.

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