Personal Data Protection Authority: Comparative Study between Indonesia, United Kingdom, and Malaysia

  • Vina Himmatus Sholikhah Airlangga University, Indonesia
  • Noering Ratu Fatheha Fauziah Sejati Airlangga University, Indonesia
  • Diyanah Shabitah Airlangga University, Indonesia


The COVID-19 pandemic has increased the number of people connected to the internet. Based on data, internet users in Indonesia increased by 8.9% from 2018 to 73.7% (APJII, 2020). In addition, internet use is increasing in residential areas and residential areas (Kominfo, 2020). The development of Information, Communication and Technology Technology continues to progress, it needs to be accompanied by data protection regulations. However, Indonesia does not yet have a data protection regulation that can be implemented on the threat of cyber attacks. This research is aimed at finding best practices in data protection that can be applied in Indonesia. This study uses the Narrative Policy Framework (NPF). In the analysis, a comparison is made between data protection authorities to protect data in Indonesia and best practices in the UK and Malaysia, especially in post-pandemic conditions. This study aims to recommend solutions that strengthen data security protection in the post-COVID-19 era in Indonesia.