COMPARATIVE LEGAL SYSTEM ANALYSIS REGARDING CONSUMER ONLINE DATA PROTECTION IN GERMANY, MALAYSIA AND INDONESIA = COMPARATIVE LEGAL SYSTEM ANALYSIS REGARDING CONSUMER ONLINE DATA PROTECTION IN GERMANY, MALAYSIA AND INDONESIA

RAFLY ZAHRANDIKA NOVIANTO (B011191392) “Comparative Legal System Analysis Regarding Consumer Online Data Protection In Germany, Malaysia And Indonesia”. Supervised by Juajir Sumardi and Maskun This study aims to compare and analyze the provision of international law and the implementation of those international law in some of the state domestic law regarding the protection of consumer data protection and the state practices of the domestic law in their region. This research uses normative legal research using Comparative approach, Analysis approach and statute approach. Types of legal material that is used in the research are primary legal sources, secondary legal sources, and tertiary legal sources collecting those material using literature review method. The result of this research is 1) there are some international instruments regarding data protection such as GDPR, COE 108+, ASEAN Framework on Data Protection, OPEC Framework on Data Protection that are being implemented in Germany, Malaysia, and Indonesia and 2) the practices of each state domestic data protection regulations can be seen in the duties of national bodies on data protection, some cases and the implementation of their national regulations.

Keywords : Data Protection, Legal System, Privacy