Personal Data Protection: 8 Urgent Actions Employers Shouldn’t Ignore Complying with Indonesia's PDP Law

Introduction: The New Era of Data Privacy Law in Indonesia

In October 2024, Indonesia officially entered a new era of data governance as the transition period for the Personal Data Protection Law (Law No. 27 of 2022) ended. Now fully in effect, the regulation establishes strict obligations for all organizations that collect, store, and process personal information, including employers.

This landmark regulation represents Indonesia’s first comprehensive data privacy law, aligning the country more closely with international standards such as the EU’s GDPR. For businesses operating in Indonesia, especially those managing employee information, this means a complete overhaul of how personal data is collected, stored, transferred, and deleted.

For employers, the stakes are high. HR departments handle some of the most sensitive information: employee identity details, payroll data, tax records, health information, and even digital performance tracking systems. Any mishandling of such data could now lead to administrative fines, civil lawsuits, and even criminal liability.

Understanding and complying with the data privacy law Indonesia framework is no longer optional, it’s a core part of corporate risk management. This article explores what every employer must know about personal data compliance and outlines eight urgent actions businesses should take to protect themselves and their employees. From obtaining valid consent and securing digital storage to appointing a Data Protection Officer, these steps are crucial for lawful and ethical data handling in Indonesia’s new regulatory landscape.

Understanding Personal Data Protection Indonesia

To comply effectively, employers must first understand what personal data protection in Indonesia truly means. Under the Personal Data Protection Law (Law No. 27 of 2022), personal data is defined as any information that can identify an individual, either directly or indirectly. This includes names, identification numbers, addresses, emails, phone numbers, or biometric data. Sensitive personal data, such as religious beliefs, health records, financial details, or criminal history, requires even stricter handling, with explicit consent from the data owner before processing.

Employees, as data subjects, now have specific rights under the data privacy law Indonesia framework. These rights include the ability to:

• Access their data and obtain information on how it’s used.
• Correct or update inaccurate or outdated information.
• Request deletion of data no longer needed for legitimate business purposes.
• Object to certain processing activities, especially those unrelated to employment obligations.

Employers must align their HR and IT systems to honor these rights efficiently, with clear procedures for handling employee requests.

The law also establishes several core principles that form the foundation of compliance:

1. Lawfulness and transparency – data must be collected with valid legal grounds and disclosed purposes.
2. Data minimization – collect only what’s necessary for legitimate operations.
3. Security and accountability – organizations are fully responsible for protecting personal data against unauthorized access or breaches.

Another critical distinction is between the Data Controller (the entity determining the purpose and method of data processing) and the Data Processor (the party processing data on behalf of the controller). In the employment context, the company acts as the Data Controller, while payroll vendors or cloud HR platforms often function as Data Processors.

Understanding these roles and obligations is the cornerstone of personal data protection Indonesia compliance. Employers must ensure that every partner and vendor adheres to the same level of security and legal responsibility.

Why Compliance Matters for Employers

Compliance with the data privacy law Indonesia is not merely a bureaucratic requirement, it’s a business necessity that directly affects legal, financial, and reputational stability. Employers in Indonesia handle an extensive range of employee data daily, from recruitment to retirement. This includes personal identification details (KTP, NPWP, passport numbers), bank and payroll data, performance reviews, health insurance information, and even digital records like CCTV footage or biometric access logs. Each data point represents both an asset and a potential liability if mishandled.

Failure to comply with data privacy law Indonesia can expose companies to serious consequences. The Personal Data Protection Law (Law No. 27 of 2022) prescribes administrative sanctions such as written warnings, temporary suspension of data processing, deletion of data, or even monetary penalties reaching up to 2% of annual revenue. In cases of criminal negligence or intentional misuse, imprisonment and criminal fines may also apply. Beyond legal exposure, businesses risk losing stakeholder trust, particularly from employees who expect their personal data to be handled with care and integrity.

Non-compliance also creates financial risks. Data breaches often result in lawsuits, compensation claims, and costly system upgrades. For companies with foreign shareholders or cross-border HR systems, the impact can extend internationally, affecting investor confidence and business reputation.

Equally important is the human factor. Employees who feel secure about how their data is used tend to show higher levels of trust and engagement. Transparent communication, consent-based data practices, and clear privacy policies reinforce the company’s credibility as a responsible employer.

In short, compliance with data privacy law Indonesia is not only about avoiding penalties, it’s about cultivating trust, ensuring operational integrity, and protecting the very people who drive the organization’s success.

8 Urgent Actions Employers Shouldn’t Ignore

To stay compliant and protect both company and employee interests, every business must adopt a proactive approach to data privacy law Indonesia. Below are eight crucial actions employers should start implementing immediately to ensure compliance with Indonesia’s Personal Data Protection Law (PDP Law).

Action 1 — Map All Employee Data Flows (Data Inventory & DPIA)

Compliance with data privacy law Indonesia begins with understanding where and how employee data moves within your organization. Employers must create a detailed data inventory that maps each stage of data handling, from collection (during recruitment or onboarding) to storage, usage, sharing, and eventual deletion. This process should identify data categories such as payroll, attendance records, medical information, and digital activity logs.

Conducting a Data Protection Impact Assessment (DPIA) helps identify risks to privacy and determine whether mitigation measures (such as encryption or pseudonymization) are required. This documentation not only ensures compliance but also serves as proof of due diligence in case of audits or disputes under data privacy law Indonesia.

Action 2 — Establish Lawful Bases & Proper Consent Documentation

Under data privacy law Indonesia, data processing must have a lawful basis, either contractual necessity, legal obligation, legitimate interest, or explicit consent. Employers should clearly define which basis applies to each data activity. For example, payroll data falls under legal obligation, while biometric attendance might require explicit consent.

Consent must be freely given, informed, and documented. Companies should maintain written consent logs or electronic records showing when and how employees agreed to data processing. HR teams can integrate consent forms within onboarding packages or HRIS systems, ensuring transparent data collection aligned with data privacy law Indonesia.

Action 3 — Update HR Policies, Privacy Notices & Employment Contracts

Every organization handling employee data must update HR policies, privacy notices, and employment contracts to align with data privacy law Indonesia. Employees should be informed about what data is collected, for what purpose, how long it’s stored, and their rights to access or correct it.

Employment contracts should now include clauses on data protection, cross-border transfers, and employee consent. Adding a PDP-compliant HR policy checklist ensures HR and management teams follow standardized privacy procedures across departments.

Action 4 — Strengthen Security Measures (Technical & Organisational)

Even the best policies fail without proper safeguards. Companies must adopt both technical and organizational measures to secure employee data in accordance with data privacy law Indonesia. This includes encrypting personal files, implementing strict access controls, maintaining secure physical archives, and practicing data minimization to limit unnecessary collection.

HR and IT teams should regularly review system vulnerabilities, conduct penetration tests, and ensure secure password and backup protocols. These steps align the company’s cybersecurity posture with national data protection standards and demonstrate compliance with personal data governance obligations.

Action 5 — Appoint a Data Protection Officer (DPO) or Privacy Lead

The data privacy law Indonesia mandates appointing a Data Protection Officer (DPO) for organizations conducting large-scale or high-risk data processing. The DPO ensures the company’s ongoing compliance, provides internal training, and acts as a liaison with authorities like the Ministry of Communication and Informatics (Kominfo).

Even when not mandatory, having a privacy lead offers strategic benefits, ensuring consistent oversight, quicker response to incidents, and a stronger culture of compliance throughout the company.

Action 6 — Prepare a Data Breach Response Plan

Data breaches can occur even in well-managed organizations. To remain compliant with data privacy law Indonesia, companies must establish a robust incident response plan. This includes immediate containment steps, internal reporting channels, and formal notifications to Kominfo and affected employees within the mandated timeline (usually 72 hours).

Employers should document every incident response step to prove accountability. Establishing a dedicated response team and clear escalation procedures ensures swift action and minimal damage if a breach occurs.

Action 7 — Manage Cross-Border Data Transfers & Third Parties

In today’s digital world, employee data often flows beyond borders, especially when companies use cloud services or regional HR systems. Under data privacy law Indonesia, transferring personal data abroad requires ensuring that the destination country provides equivalent protection standards.

Employers must include data protection clauses in contracts with third-party vendors, conduct privacy audits, and use standard contractual clauses (SCCs) or other legal safeguards. These practices help maintain full compliance with data privacy law Indonesia, ensuring employee data remains protected even outside national jurisdiction.

Action 8 — Train Employees & Maintain Compliance Records

Compliance is only sustainable when embedded in the company culture. Regular privacy training for HR, legal, and IT departments helps employees understand their obligations under data privacy law Indonesia. Training should cover how to handle personal data securely, respond to access requests, and recognize potential breaches.

Additionally, maintaining accurate compliance records, such as training logs, audit results, and consent registers, provides strong evidence of due diligence during inspections. Cultivating awareness at every level of the organization ensures long-term resilience and reinforces a company-wide commitment to responsible data management.

Consent Documentation Best Practices

Proper consent management is one of the core requirements under data privacy law Indonesia, ensuring that employee personal data is collected and processed transparently. Employers should use a written consent format that clearly outlines what data will be collected, for what purposes, and for how long it will be retained. Each consent form must be written in clear, understandable language, avoiding legal jargon and must include an explicit acknowledgment section for the employee’s agreement.

Importantly, employers must separate consents for different processing purposes. For example, consent for payroll processing should not automatically include permission for marketing use or sharing with third-party vendors. This separation helps demonstrate compliance with the data privacy law Indonesia principle of informed and specific consent.

Companies should also maintain a secure digital or physical archive of consent forms, including timestamps, versions, and employee identifiers. Having a reliable system for retrieving consent history is crucial for audits, legal inquiries, or data subject requests. Furthermore, employees must have the right and clear instructions, to withdraw consent at any time, with the withdrawal process being as easy as giving consent. This proactive documentation not only fulfills legal obligations but also builds transparency and trust between employer and employee.

Enforcement & Penalties

Since the full implementation of the data privacy law Indonesia on 17 October 2024, regulators have intensified oversight to ensure that both local and foreign employers comply with employee data protection obligations. The law introduces three layers of sanctions, administrative, civil, and criminal, depending on the severity of violations and the level of negligence or intent.

Administrative fines may reach up to 2% of a company’s annual revenue for certain infringements, such as processing data without consent, failing to report breaches, or transferring data abroad without safeguards. In addition, regulators may impose corrective orders, suspend data processing, or even revoke business licenses in extreme cases.

From a civil perspective, employees (as data subjects) can sue companies for damages if their personal data is misused, leaked, or processed unlawfully. Criminal penalties apply to intentional misuse, such as selling or unlawfully disclosing sensitive personal data, punishable by imprisonment and heavy fines under the data privacy law Indonesia.

While Indonesia’s Data Protection Authority is still in the formation stage, enforcement is already being supported by the Ministry of Communication and Information Technology (Kominfo) and other regulators. Post-2024, companies are expected to show “accountability”, meaning clear documentation of consent, risk assessments, and security measures. Employers that proactively demonstrate compliance through internal audits, staff training, and transparent communication will significantly reduce their exposure to legal and reputational risks. In essence, the new enforcement era rewards readiness, not reaction.

90-Day Employer Compliance Roadmap

Achieving full alignment with the data privacy law Indonesia doesn’t have to be overwhelming. With a structured 90-day plan, employers can progressively build compliance while maintaining daily operations. The key is to prioritize actions that demonstrate accountability and reduce exposure early.

Days 1–30: Assess & Map

Start with a data audit, identify what employee data you collect, where it’s stored, who accesses it, and how long it’s retained. Conduct a Data Protection Impact Assessment (DPIA) to highlight high-risk areas, especially in HR, payroll, and recruitment systems.

Days 31–60: Build Policies & Procedures

Draft or update employee privacy policies, consent forms, and HR contracts. Appoint a Data Protection Officer or assign a privacy lead. Establish internal SOPs for data access, breach response, and third-party vendor compliance.

Days 61–90: Implement & Educate

Roll out security measures (encryption, restricted access, password protocols) and test breach notification procedures. Train HR, legal, and IT teams on data handling best practices and documentation. Maintain a compliance record and log all policy updates for audit readiness.

By following this 90-day roadmap, businesses can confidently demonstrate good-faith efforts toward compliance with the data privacy law Indonesia, protecting not only their employees’ personal data but also their company’s reputation and legal standing.

Building Trust Through Lasting Compliance

As Indonesia fully enforces its Personal Data Protection (PDP) Law, compliance is no longer a choice, it’s a necessity. For employers, aligning with the data privacy law Indonesia is about more than avoiding fines; it’s about demonstrating integrity, professionalism, and respect for employees’ rights.

The eight urgent actions outlined in this guide, from mapping data flows to appointing a DPO and managing cross-border transfers, form a practical foundation for long-term privacy governance. By embedding these steps into daily HR and IT processes, companies ensure both regulatory compliance and operational resilience.

True compliance with the data privacy law Indonesia is not a one-time project but an ongoing journey. Regular reviews, employee training, and proactive updates to policies will keep businesses aligned with evolving standards.

Ultimately, companies that prioritize data privacy law Indonesia not only protect themselves from legal and financial risks but also cultivate trust, a powerful asset that strengthens employer reputation, attracts top talent, and sustains business growth in the digital era.