D15 · Personal data: retention and anonymizing

Accepted · 2026-10-02 · zuki

Decision: before cutover, v2 has a written retention rule for each kind of personal data, rejected leads included; an app.anonymize_driver() function that scrubs identity fields and deletes the person's files while keeping money and audit rows; and a breach procedure. A lawyer reviews them before go-live. Retention periods are OQ18.

Why: GR 33/2026, the implementing regulation of Indonesia's personal data protection law, takes effect on 16 January 2027. It requires a retention policy, deletion on request within 3×24 hours and breach notification within 72 hours. P13 (business rows are never hard-deleted) still holds; anonymizing is how a deletion request is met.