The Staff Privacy Notice is a mandatory document under Indonesian data protection law, specifically required following the implementation of the Personal Data Protection Law (PDP Law) No. 27 of 2022. It serves as a formal notification to employees about how their personal data is collected, processed, and protected within the organization. This document should be provided to all employees at the start of their employment and updated as necessary to reflect changes in data processing practices or legal requirements. The notice must address specific requirements under Indonesian law regarding consent, data subject rights, retention periods, and security measures, while also considering any cross-border data transfer requirements for international organizations. It forms a crucial part of an organization's data protection compliance framework and helps establish transparency in employer-employee relationships regarding personal data handling.
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1. Introduction: Overview of the privacy notice and its importance
2. Scope and Application: Who the privacy notice applies to and when it applies
3. Types of Personal Data Collected: Comprehensive list of personal data categories collected from employees
4. Purposes of Data Processing: Detailed explanation of why and how personal data is collected and used
5. Legal Basis for Processing: Legal grounds under Indonesian law for processing personal data
6. Data Retention Periods: How long different types of personal data are kept
7. Data Security Measures: Methods used to protect employee personal data
8. Employee Rights: Rights under PDP Law including access, correction, and deletion rights
9. Data Sharing and Disclosure: Information about third parties who may receive employee data
10. Contact Information: Details of data protection officer or responsible person for privacy queries
1. International Data Transfers: Include if employee data is transferred outside Indonesia
2. Automated Decision Making: Include if any automated processing or profiling is used
3. Special Categories of Data: Include if processing sensitive data like health information or religious beliefs
4. CCTV and Monitoring: Include if workplace surveillance or monitoring systems are used
5. Remote Working Data Processing: Include if employees work remotely and special data processing applies
6. Biometric Data Processing: Include if collecting biometric data for attendance or security
1. Data Categories Matrix: Detailed table of data types, purposes, retention periods, and legal bases
2. Third Party Processors List: List of approved data processors and their roles
3. Security Protocols: Detailed information about specific security measures and procedures
4. Data Subject Rights Procedure: Step-by-step guide for exercising data subject rights
5. Incident Response Plan: Procedures for handling data breaches and security incidents
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