I’m a big believer in small steps. Making progress every day, even just a bit, keeps me going.
Right now, that means immersing myself in my future project for KIPP: ‘Data Security for State Institutions in Indonesia.’ Still, I’m grappling with exactly which aspect of data management I should focus on.
The backbone of my research is the Personal Data Protection Law (UU No. 27 Tahun 2022), which outlines several key security standards for managing personal data. Among these are:
- Data Protection Impact Assessments – Requires data controllers to conduct risk assessments for large-scale data processing, automated decision-making, new technology, and any processing that restricts data subjects’ rights.
- Operational Security Measures – Data controllers must ensure data protection through suitable technical measures and security levels aligned with the data’s risk level.
- Monitoring and Unauthorized Access Prevention – Data controllers should safeguard data confidentiality, oversee third-party involvement, and maintain a robust security system.
- Purpose-Limited Processing – Ensures data is processed accurately and responsibly to protect the rights of data subjects.
- Transparency and Accountability – Guarantees open processing practices, provides data access to subjects, and clearly communicates processes in an accessible manner.
For my project, I’m zeroing in on points 2 and 3. I think my ‘future expertise’ could help organizations create a framework for data management practices by Payment Service Providers (we called is as PJP) in Indonesia. Plus, it would establish protocols for monitoring and preventing unauthorized access to meet PDP Law requirements.
Explaining the benchmarking research on BoE: To deepen my understanding, I’ve done some initial benchmarking on data privacy and security management with central banks, specifically the Bank of England, which has been my host during my time here. In the UK, the Information Commissioner’s Office (ICO) oversees Payment Service Providers, similar to how data privacy is regulated by Indonesia’s Ministry of Communication. However, considering recent data breaches back home, it’s clear we have some catching up to do.
Back to the topic! When it comes to PSP oversight and data security standards, BoE has laid out several significant steps:
- Outsourcing and Third-Party Risk Management [link]:
- Data Protection in Outsourcing Agreements: Banks and PSPs must define, document, and understand their responsibilities related to data transfers.
- Rights to Access, Audit, and Information: Banks have the right to access and audit third-party service providers, ensuring their adherence to data security standards.
- Sub-outsourcing: Banks must ensure that any subcontractors also meet data protection standards.
- Operational Resilience [link]: BoE emphasizes that PSPs should have resilient systems capable of withstanding disruptions, including personal data breaches.
- Privacy Policy Commitments [link]: BoE is committed to protecting individual privacy, ensuring personal data processing aligns with established principles.
This benchmarking exercise will be instrumental in shaping my project. I’m likely to cover the following aspects:
- Security Standards Identification
- Framework Design
- Audit and Monitoring Procedures
- Best Practices in Technology and Procedures
I think these steps could serve as practical guidelines not only for the office but also for PJP data protection practices across Indonesia.