IndonesiaLaw on Personal Data Protection, biometric data definition
Law No. 27 of 2022 on Personal Data Protection, Article 4(2)(b) and its official elucidation
In force since .
A biometric privacy rule binding public and private bodies.
- Excludes recording-derived identifiers
- No
- Audit expectation
- none
What it requires
- An app that derives a faceprint, voiceprint, or other biometric identifier from an individual in Indonesia must treat it as specific personal data under Article 4 and obtain the stricter consent Article 21 requires for that category.
These lines are LexLint's reading of the law's text.
In the frameworks
- NIST Privacy Framework
- CT.PO-P1Policies, processes, and procedures for authorizing data processing (e.g., organizational decisions, individual consent), revoking authorizations, and maintaining authorizations are established and in place.
Our reading of where this law's duties sit in each framework. It never says that running a control meets the law. How we read a framework against the law
Who enforces it
Settledness
- As of
- Open questions
- Is a 'gambar wajah' ('facial image') that is not used to identify an individual uniquely still 'data biometrik' ('biometric data') under the elucidation to Article 4(2)(b) of Law No. 27 of 2022?
What it makes you log
Logging duty
Article 4(2)(b) lists biometric data among specific personal data, and the official elucidation explains the term. A classification of data asks the controller for no log or record.
- Kind
- None
- As of
What this law does
Article 4 distinguishes specific personal data (the sensitive category) from general personal data, listing biometric data among health data, genetic data, criminal records, children's data, and personal financial data. The official elucidation to Article 4(2)(b) defines biometric data as data relating to a person's physical, physiological, or behavioral characteristics enabling unique identification, naming a facial image expressly as an example alongside fingerprint, retinal, and DNA data.
A direct search for suara (voice) in the elucidation returned zero hits, so voiceprint coverage rests on the general definitional language rather than an express example. As specific personal data, biometric data processing requires stricter consent under Article 21 and related provisions.
When LexLint raises it
When your app profile says your app processes biometric data.
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