Indonesia UU PDP Law No. 27/2022 Technical Checklist for Software Engineers and Data Controllers
A practical engineering checklist for implementing Indonesia's Personal Data Protection Law (UU No. 27 Tahun 2022 tentang Pelindungan Data Pribadi) alongside international GDPR and CCPA standards.
Indonesia's Law No. 27 of 2022 on Personal Data Protection (UU PDP) establishes comprehensive statutory obligations for every organization that collects or processes personal data of Indonesian citizens, whether the organization is domiciled inside or outside Indonesia. Modeled closely on the European Union's General Data Protection Regulation (GDPR), UU PDP requires software engineers to bake privacy guarantees directly into their application architecture.
1. Five Mandatory Engineering Controls Under UU PDP
- 1. Explicit Legal Basis Logging (Article 20 UU PDP): Every personal data processing activity must map to a valid legal basis (explicit consent, contractual necessity, legal obligation, vital interest, public task, or legitimate interest). Consent timestamps and policy versions must be immutably logged.
- 2. Separation of Specific (Sensitive) vs. General Personal Data (Articles 3 & 4): Personal finance records, health data, biometrics, and children's data require heightened encryption at rest (AES-256) and strict role-based access control (RBAC). On GajiWajar.id and PantasNaik.id, compensation benchmarks are decoupled from personal identifiers.
- 3. Automated Data Subject Rights Execution (Articles 5 to 13): Systems must support user requests to access, correct, export (data portability), withdraw consent, and permanently erase their personal data within statutory SLA windows (3 x 24 hours for access/rectification workflows).
- 4. Record of Processing Activities (RoPA - Article 31): Data controllers must maintain audit logs of all data processing flows, retention schedules, and sub-processors.
- 5. 72-Hour Incident Response Pipeline (Article 46): Automated intrusion detection and incident response runbooks capable of notifying affected users and regulators within 3 x 24 hours (72 hours) in the event of a security breach.
2. How PT. Think Era Labs Implements Multi-Jurisdictional Privacy
"By aligning our core data architecture with the strictest union of Indonesian UU PDP, EU GDPR, and California CCPA standards, our consumer platforms protect user sovereignty by default."
You can review our full statutory disclosures and data subject rights procedures in our bilingual Privacy Policy and Cookie & PSE Compliance Policy.