Bank Secrecy And Data Protection In Indonesia

Banks in Indonesia are subject to bank secrecy/confidentiality obligations grounded in Law No. 7 of 1992 regarding Banking, as lastly amended by Law No. 10 of 1998 (the "Banking Law"). Under the Banking Law, banks and their affiliates are required to keep confidential information regarding its depositing customers as well as any sum deposited by such customers. This confidentiality obligation does not cover information provided by non-depositing customers.

This is further strengthened by BI Regulation No. 7/6/PBI/2005 regarding Transparency of Information of Bank Products and the Use of Customer Personal Data ("BI Reg. 7/2005"). Under this BI regulation, banks are obligated to ask for written approval from customers before the banks can provide and/or disseminate their customers' personal data to other parties for commercial purposes, unless stipulated otherwise under the applicable laws and regulations. The personal data of customers thus protected is (i) name of