Strengthening Personal Data Protection in Indonesian Digital Financial Services through an Accountability Based Legal Framework

Abstract

The rapid expansion of digital financial services in Indonesia has increased the volume and complexity of personal data collection, processing, storage, and transfer, creating significant legal challenges concerning privacy, consumer protection, accountability, and effective remedies. This study examines the legal protection of personal data users in Indonesian digital financial services, identifies legal problems arising from personal data misuse, and formulates strategies for strengthening the existing protection framework. The study employs normative legal research using statutory, conceptual, and case approaches. Primary legal materials include legislation and financial-sector regulations governing personal data protection, consumer protection, electronic transactions, banking, fintech, and financial services, supported by relevant judicial decisions and scholarly literature. The findings demonstrate that Indonesian law has established a relatively comprehensive framework through the Personal Data Protection Law and sectoral financial regulations, but regulatory fragmentation, overlapping institutional responsibilities, difficulties in establishing liability, third-party data processing, and limited consumer access to remedies remain significant challenges. Personal data violations may generate administrative, civil, and criminal consequences depending on the nature of the conduct and resulting harm. The study proposes an accountability-based framework integrating regulatory harmonization, lifecycle-based data governance, institutional supervision, privacy by design, consumer empowerment, breach-response mechanisms, and accessible remedies. The proposed framework strengthens the connection between legal rights and institutional accountability while supporting responsible digital financial innovation. The study contributes a normative legal model for improving personal data protection and consumer confidence within Indonesia’s evolving digital financial ecosystem.