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Intra Group Data Transfer Agreement
"I need an Intra Group Data Transfer Agreement for transferring customer and employee data between our Jakarta headquarters and three Indonesian subsidiary companies in the banking sector, with specific provisions for financial data security compliance."
1. Parties: Identification of the group entities participating in the data transfer agreement, including their registration details and addresses
2. Background: Context of the agreement, relationship between the parties, and purpose of the data transfer arrangement within the group
3. Definitions: Definitions of key terms used in the agreement, including technical terms, data categories, and regulatory references
4. Scope and Purpose: Detailed description of the data transfer activities covered and their legitimate business purposes
5. Data Protection Principles: Commitment to comply with Indonesian data protection principles as per the PDP Law
6. Obligations of Data Transferor: Responsibilities of the entity transferring the data, including data quality and legal basis for transfer
7. Obligations of Data Recipient: Responsibilities of the receiving entity, including security measures and processing limitations
8. Security Measures: Technical and organizational measures required to protect the transferred data
9. Data Subject Rights: Procedures for handling data subject requests and ensuring their rights are protected
10. Breach Notification: Procedures for reporting and handling data breach incidents
11. Audit Rights: Rights and procedures for conducting compliance audits
12. Liability and Indemnification: Allocation of liability and indemnification obligations between parties
13. Term and Termination: Duration of the agreement and conditions for termination
14. General Provisions: Standard contractual provisions including governing law, dispute resolution, and notices
1. Sub-processing: Include when data recipients may engage sub-processors for data processing activities
2. Cross-border Transfers: Include when data transfers may occur outside of Indonesia
3. Data Retention and Deletion: Include when specific retention periods or deletion procedures need to be established
4. Business Continuity: Include when critical data requires specific disaster recovery procedures
5. Cost Allocation: Include when there are specific cost-sharing arrangements for data protection measures
6. Industry-Specific Requirements: Include when transfers involve regulated industries (e.g., financial services, healthcare)
1. Schedule 1 - Categories of Data: Detailed list of personal data categories being transferred
2. Schedule 2 - Processing Activities: Description of authorized processing activities and purposes
3. Schedule 3 - Security Measures: Detailed technical and organizational security measures
4. Schedule 4 - Transfer Mechanisms: Specific procedures and tools used for data transfers
5. Schedule 5 - Contact Points: List of key contacts for operational and emergency matters
6. Appendix A - Data Processing Register: Template for maintaining records of processing activities
7. Appendix B - Breach Notification Form: Standard form for reporting data breaches
8. Appendix C - Audit Checklist: Standard checklist for compliance audits
Authors
Financial Services
Technology
Manufacturing
Healthcare
Retail
Telecommunications
Professional Services
Energy
Transportation
Consumer Goods
Insurance
Mining
E-commerce
Education
Legal
Compliance
Information Technology
Information Security
Risk Management
Data Protection
Corporate Governance
Internal Audit
Privacy
Operations
Information Management
Chief Legal Officer
Data Protection Officer
Privacy Manager
Compliance Director
Legal Counsel
Information Security Manager
IT Director
Risk Management Officer
Corporate Secretary
Chief Information Officer
Chief Technology Officer
Head of Compliance
Privacy Counsel
Information Governance Manager
Data Protection Specialist
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