Indonesia does not have a single, overarching data protection law like the GDPR. Instead, it has a complex web of sectoral regulations (e.g., MOCI 20/2016 for electronic systems, OJK regulations for finance). The foundational and critical step is to map the data flows and processing activities against the specific regulations that govern them. Relying on GDPR templates or a generic consent-first approach fails to address the nuanced, sector-specific requirements that are characteristic of the Indonesian legal landscape.

A core structural difference is the APPI’s focus on ‘personal information databases’ held by business operators. Many obligations (like certain data subject rights) are triggered specifically for ‘retained personal data’ within such databases. The GDPR’s scope of ‘processing’ is broader and more activity-based. While Japan has the Personal Information Protection Commission (PPC) as a supervisory body, the key rebuttal lies in the substantive, scope-based difference in how the laws apply, not just the institutional structure.

Data protection laws often have extraterritorial or territorial application. While the contractual governing law is Singapore’s PDPA, the physical processing activity (storage, potential breach) occurs within Malaysia’s jurisdiction. Malaysia’s PDPA 2010 applies to data processors processing personal data in Malaysia, regardless of the data subjects’ nationality. Therefore, the Malaysian authority could assert jurisdiction over the vendor’s operations in Malaysia. A privacy professional must consider both the contractual law and the laws of the territory where processing physically occurs.

South Korea’s PIPA has strict rules for international transfers. The primary legal basis is the data subject’s consent, which must be specific, informed, and voluntary. PIPA requires that consent be obtained after notifying the individual of specific details about the overseas recipient. Exceptions like ‘performance of a contract’ or ‘legitimate interests’ as understood under the GDPR are not standard, reliable bases under PIPA’s strict framework for cross-border data transfers. BCRs are a mechanism under EU law, not directly recognized under PIPA without consent or other specific provisions.

Under Thailand’s PDPA, the appointment of a DPO is mandatory for data controllers or processors whose core activities involve regular monitoring of personal data on a large scale, or the processing of sensitive personal data on a large scale. A publicly traded bank engaging in systematic monitoring of financial transactions for security and compliance would clearly fall under this ‘large-scale systematic monitoring’ criterion. The requirement is not universal; it is triggered by the scale, sensitivity, and nature of the processing activities.

The ‘core of necessity’ principle in China’s PIPL is a robust expression of data minimization and purpose limitation. It requires that the collection and processing of personal information be limited to the minimum scope necessary to achieve the purposes directly related to the specific handling activities. It is a proactive obligation to justify the scope and scale of data processing from the outset, going beyond mere notice and shaping system design and business processes.

The Philippine DPA itself states notification should be made ‘within the period prescribed by the Commission.’ The NPC, through its Circular 16-03, has prescribed that the period for breach notification to the NPC is 72 hours from knowledge of the breach, but specifically for incidents that pose a real risk of serious harm. This creates a two-step analysis: 1) Determine if there’s a real risk of serious harm, and 2) if yes, notify the NPC within 72 hours. This is a nuanced implementation detail a CIPP-A professional must know.

The DPDPA’s ‘deemed consent’ includes specific, enumerated situations where consent is assumed without explicit action. One key category is ‘for purposes related to employment.’ Processing employee data for legitimate employment purposes like payroll, benefits, or providing necessary tools falls under this provision. The other options describe practices that would not qualify: unsolicited marketing requires explicit consent, bundling consent in an unread policy is not valid, and processing publicly available data is subject to its own specific rules and may not automatically qualify as deemed consent for advertising.

Vietnam’s data localization mandate under the Law on Cybersecurity is targeted. It specifically applies to ‘personal information of service users in Vietnam’ collected, analyzed, and processed by providers of certain services, notably telecommunications services, internet-based value-added services (which include social networks and online messaging), and cyberspace storage and sharing. It is not a blanket requirement for all personal data or all companies, but a focused mandate on specific service providers and data types.

Indonesia does not have a single, overarching data protection law like the GDPR. Instead, it has a complex web of sectoral regulations (e.g., MOCI 20/2016 for electronic systems, OJK regulations for finance). The foundational and critical step is to map the data flows and processing activities against the specific regulations that govern them. Relying on GDPR templates or a generic consent-first approach fails to address the nuanced, sector-specific requirements that are characteristic of the Indonesian legal landscape.0