Data Privacy and Cybersecurity Indonesia & Singapore Law


Marshall Situmorang and Audria Putri | Nusantara Legal Partnership

Data Privacy and Cybersecurity Comparative Guide

A. Definition and Scope of Data Privacy and Cybersecurity

Data Privacy

  1. Is there any specific definition of “personal data” in your jurisdiction? Do the prevailing laws provide distinction between personal data and sensitive personal data?

Personal data is defined as “a certain personal data that is stored, maintained, kept true and its confidentiality is protected” (Art. 1 (1) of Minister of Communications and Informatics (“MoCI”) Regulation No. 20 of 2016 on Personal Data Protection within the Electronic System (“MoCI Regulation 20/2016”)). However, the applicable laws and regulations on personal data protection in Indonesia do not provide any specific definition of “sensitive personal data” and are silent on these matters.

Therefore, there is no clear distinction between “personal data” and “sensitive personal data”.

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