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Data Protection Addendum
"I need a Data Protection Addendum for my Indonesian e-commerce company acting as a data controller, engaging a cloud service provider in Singapore for customer data storage starting March 2025, with specific focus on cross-border data transfers and security measures."
1. Parties: Identification of the parties entering into the addendum, including their roles as data controller and/or data processor
2. Background: Context of the addendum, reference to the main agreement, and purpose of the data processing relationship
3. Definitions: Key terms used in the addendum, aligned with Indonesian PDP Law definitions including Personal Data, Processing, Controller, Processor, and Data Subject
4. Scope and Purpose: Detailed description of the personal data processing activities covered by the addendum
5. Roles and Responsibilities: Clear delineation of each party's role and obligations under Indonesian data protection law
6. Data Processing Requirements: Specific requirements for lawful processing, including consent mechanisms, purpose limitation, and data minimization
7. Data Security Measures: Technical and organizational measures required to protect personal data
8. Data Subject Rights: Procedures for handling data subject requests and ensuring compliance with PDP Law rights
9. Data Breach Notification: Procedures and timeframes for reporting data breaches as per Indonesian regulations
10. Cross-border Data Transfers: Requirements and safeguards for international data transfers under Indonesian law
11. Term and Termination: Duration of the addendum and conditions for termination
12. Return or Deletion of Data: Obligations regarding personal data upon termination of services
13. Governing Law and Jurisdiction: Confirmation of Indonesian law application and jurisdiction
1. Audit Rights: Optional section detailing the controller's right to audit the processor's compliance, useful for high-risk processing activities
2. Sub-processing: Required if the processor intends to engage sub-processors, including authorization requirements and obligations
3. Insurance Requirements: Optional section specifying insurance obligations for data protection risks, relevant for high-value or high-risk processing
4. Special Categories of Personal Data: Required only if sensitive personal data is being processed, detailing additional safeguards
5. Data Protection Impact Assessment: Optional section required for high-risk processing activities
6. Industry-Specific Requirements: Required for regulated sectors like financial services or healthcare, incorporating sector-specific obligations
1. Schedule 1 - Details of Processing: Detailed description of processing activities, categories of data subjects, types of personal data, and processing purposes
2. Schedule 2 - Technical and Organizational Measures: Detailed security measures and controls implemented to protect personal data
3. Schedule 3 - Approved Sub-processors: List of approved sub-processors and their processing activities, if applicable
4. Schedule 4 - Transfer Mechanisms: Details of cross-border transfer mechanisms and safeguards
5. Schedule 5 - Data Subject Request Procedure: Detailed procedures for handling data subject rights requests
6. Appendix A - Contact Details: Contact information for data protection officers and key personnel responsible for data protection
Authors
Technology
Financial Services
Healthcare
E-commerce
Telecommunications
Education
Professional Services
Manufacturing
Retail
Insurance
Transportation and Logistics
Hospitality
Media and Entertainment
Legal
Compliance
Information Security
IT
Privacy
Risk Management
Procurement
Operations
Vendor Management
Data Protection
Chief Privacy Officer
Data Protection Officer
Chief Information Security Officer
Privacy Counsel
Legal Counsel
Compliance Manager
Information Security Manager
Risk Manager
IT Director
Chief Technology Officer
Procurement Manager
Vendor Management Officer
Operations Director
Chief Operating Officer
Chief Legal Officer
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