Personal Data Protection Analysis : Comparison of Indonesia, the United States as Federal Countries

Personal data protection is a crucial issue in the digital era, which is characterized by the processing and widespread dissemination of information on the internet. In this context, the different legal approaches between Indonesia and the United States raise questions regarding the effectiveness and scope of privacy protection in each country. The focus of this research is to analyze the legal systems applicable in both countries to identify the strengths, weaknesses, and potential for cross-system policy adoption. Using a normative juridical method and a comparative law approach, analysis is conducted on key regulations such as Law No. 27 of 2022 in Indonesia as well as various sectoral regulations in the United States. The findings show that Indonesia has integrated regulations but faces challenges in implementation, while the United States has more established enforcement despite its sectoral and fragmented nature. The synthesis of these two approaches emphasizes the importance of finding a balance between regulatory comprehensiveness and enforcement effectiveness. In conclusion, efforts to strengthen personal data protection in Indonesia can be directed towards strengthening institutions and oversight, while the United States can draw lessons from its centralized regulatory model to improve consistency of protection across sectors.

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Publication Details

Journal
International Journal of Law, Crime and Justice
Published
2025-06-17
DOI
https://doi.org/10.62951/ijlcj.v2i2.583
Primary Topic
Legal and Social Justice Studies
Type
article
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article

Personal Data Protection Analysis : Comparison of Indonesia, the United States as Federal Countries

Sevy Septiana Afina, Rina Arum Prastyanti
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International Journal of Law, Crime and Justice
Legal and Social Justice Studies
article

Personal Data Protection Analysis : Comparison of Indonesia, the United States as Federal Countries

Sevy Septiana Afina, Rina Arum Prastyanti
article en

Abstract

Personal data protection is a crucial issue in the digital era, which is characterized by the processing and widespread dissemination of information on the internet. In this context, the different legal approaches between Indonesia and the United States raise questions regarding the effectiveness and scope of privacy protection in each country. The focus of this research is to analyze the legal systems applicable in both countries to identify the strengths, weaknesses, and potential for cross-system policy adoption. Using a normative juridical method and a comparative law approach, analysis is conducted on key regulations such as Law No. 27 of 2022 in Indonesia as well as various sectoral regulations in the United States. The findings show that Indonesia has integrated regulations but faces challenges in implementation, while the United States has more established enforcement despite its sectoral and fragmented nature. The synthesis of these two approaches emphasizes the importance of finding a balance between regulatory comprehensiveness and enforcement effectiveness. In conclusion, efforts to strengthen personal data protection in Indonesia can be directed towards strengthening institutions and oversight, while the United States can draw lessons from its centralized regulatory model to improve consistency of protection across sectors.

International Journal of Law, Crime and JusticeVol. 2(2)
Universitas Nusa Bangsa (ID)
Openalex Percentile: Top 64%
Legal and Social Justice Studies
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Personal Data Protection Analysis : Comparison of Indonesia, the United States as Federal Countries — Sevy Septiana Afina, Rina Arum Prastyanti · International Journal of Law, Crime and Justice (2025) | TGRS Research Map | TGRS