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Joint Controller Data Processing Agreement

Joint Controller Data Processing Agreement Template for Indonesia

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Key Requirements PROMPT example:

Joint Controller Data Processing Agreement

"I need a Joint Controller Data Processing Agreement under Indonesian law for a partnership between an e-commerce platform and a payment provider, with specific focus on customer data sharing and joint marketing activities starting March 2025."

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Document background
This Joint Controller Data Processing Agreement is essential when two or more organizations jointly determine the purposes and means of processing personal data in Indonesia. It is specifically designed to comply with Indonesia's Personal Data Protection Law (UU No. 27/2022) and related regulations, including Government Regulation No. 71 of 2019 on Electronic Systems and Transactions. The agreement becomes necessary in scenarios such as joint ventures, shared services arrangements, or collaborative projects where multiple parties have control over data processing decisions. It establishes clear protocols for data protection, defines respective responsibilities, ensures proper handling of data subject rights, and sets out liability arrangements between the controllers. This document is particularly important given Indonesia's strengthened data protection framework and the increasing scrutiny of joint processing arrangements by regulatory authorities.
Suggested Sections

1. Parties: Identification of the joint controllers entering into the agreement, including their full legal names, registration numbers, and registered addresses

2. Background: Context of the agreement, description of the joint processing activities, and the relationship between the parties

3. Definitions: Definitions of key terms used in the agreement, including those from Indonesian PDP Law and other relevant regulations

4. Scope and Purpose: Detailed description of the joint processing activities, types of personal data involved, and purposes of processing

5. Roles and Responsibilities: Clear allocation of responsibilities between joint controllers, including primary point of contact for data subjects

6. Compliance with Data Protection Laws: Obligations to comply with Indonesian PDP Law and other relevant regulations

7. Data Subject Rights: Procedures for handling data subject requests and ensuring their rights under Indonesian law

8. Security Measures: Technical and organizational measures required to protect personal data

9. Data Breach Notification: Procedures for handling and reporting personal data breaches

10. Liability and Indemnification: Distribution of liability between joint controllers and indemnification provisions

11. Term and Termination: Duration of the agreement and conditions for termination

12. Governing Law and Jurisdiction: Confirmation of Indonesian law as governing law and jurisdiction for disputes

Optional Sections

1. International Data Transfers: Required when personal data will be transferred outside Indonesia, including compliance with cross-border transfer requirements

2. Sub-processing: Include when either party may engage sub-processors for data processing activities

3. Insurance: Include when specific insurance requirements need to be maintained by the parties

4. Audit Rights: Include when parties want to establish specific audit procedures beyond statutory requirements

5. Industry-Specific Compliance: Include when processing activities involve regulated sectors (e.g., financial services, healthcare)

6. Data Protection Impact Assessment: Include when high-risk processing activities require specific DPIA procedures

Suggested Schedules

1. Schedule 1 - Processing Activities: Detailed description of processing activities, categories of data subjects, and types of personal data

2. Schedule 2 - Technical and Organizational Measures: Detailed security measures and controls implemented by both parties

3. Schedule 3 - Data Subject Rights Procedure: Detailed procedures for handling data subject requests

4. Schedule 4 - Data Breach Response Plan: Detailed procedures for responding to and reporting data breaches

5. Schedule 5 - Contact Points: List of key contacts for operational, technical, and legal matters

6. Schedule 6 - Sub-processors: List of approved sub-processors and their processing activities

7. Appendix A - Data Flow Diagram: Visual representation of data flows between joint controllers and any third parties

Authors

Alex Denne

Head of Growth (Open Source Law) @ tiktok成人版 | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

alex.den.21@genieai.co
Relevant legal definitions




































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Relevant Industries

Financial Services

Healthcare

E-commerce

Technology

Telecommunications

Education

Insurance

Manufacturing

Retail

Professional Services

Transportation and Logistics

Real Estate

Media and Entertainment

Energy and Utilities

Relevant Teams

Legal

Compliance

Information Security

IT

Risk Management

Data Protection

Operations

Privacy

Corporate Governance

Information Management

Business Development

Project Management

Relevant Roles

Chief Privacy Officer

Data Protection Officer

Legal Counsel

Compliance Manager

Information Security Manager

Risk Manager

Chief Information Security Officer

Chief Technology Officer

Privacy Manager

General Counsel

IT Director

Operations Director

Commercial Director

Business Development Manager

Project Manager

Industries





Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks, 聽Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination, 聽Severance Pay, Governing Law, Entire Agreemen

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