Alignment recheck

The old controller's destruction undertaking at RPP Pasal 144 ayat (2) huruf e survives at PP Pasal 133 ayat (3) huruf g in changed legal form, as a pernyataan inside the notification to data subjects rather than a required term of the agreement between the two controllers. The current title reads as a deletion of the destruction duty, so it is rewritten to say where the duty went.

The add list stays empty because PP Pasal 133 runs to 3395 characters and breaches the panel length cap, so the survival is carried in the rewritten what changed and analysis instead.

Undercount of the dropped clauses. The what_changed names only three RPP requirements (the purpose limit, the failed transaction return, the old controller's destruction) and says PP Pasal 134 ayat (2) 'carries none of the three'. RPP Pasal 144 ayat (2) huruf b also disappears and is never mentioned: 'pemberian akses Data Pribadi Pengendali Data Pribadi lama kepada Pengendali Data Pribadi baru diberikan sepanjang transaksi berlangsung', a duration limit on the new controller's access.

The two provisions are not different objects, one sits inside the other. PP Pasal 171 ayat (1) locates peraturan korporasi yang mengikat inside Pasal 169 ayat (1) huruf c, and PP Pasal 172, the next article, delegates pelaksanaan Pelindungan Data Pribadi yang memadai dan bersifat mengikat, which the finding itself treats as the Pasal 165 ayat (2) limb that an incomplete set of rules would breach.

The enacted text delegates by route where the draft delegated by instrument, so RPP Pasal 188 ayat (4) is absorbed, not deleted, and striking it says no delegation reaches binding corporate rules.

Check 1 fails. PP Pasal 172 does not contain the clause the recast needs. Its object is "pelaksanaan Pelindungan Data Pribadi yang memadai dan bersifat mengikat", a route. It never names peraturan korporasi yang mengikat, which RPP Pasal 188 ayat (4) names in terms. The containment claim rests entirely on PP Pasal 169 ayat (1) huruf c, which the brief does not quote. The proposal concedes this.

Under the evidence rules that is verdict "unsettled", not "recast", with add lists empty.

Both provisions govern the same object, consent as the basis for transferring personal data out of the jurisdiction. RPP Pasal 190 ayat (3) delegates transfer Data Pribadi berdasarkan persetujuan, and PP Pasal 174 delegates pelaksanaan persetujuan untuk transfer Data Pribadi ke luar wilayah hukum Negara Republik Indonesia, sitting directly after Pasal 173, the enacted consent article the finding already cites.

The clause moved out of the ayat and became a standalone article. Striking it as deleted states that the consent route lost its Peraturan Lembaga hook, which the enacted text contradicts.

The core verdict survives. PP Pasal 174 does contain the clause in substance: "Ketentuan lebih lanjut mengenai pelaksanaan persetujuan untuk transfer Data Pribadi ke luar wilayah hukum Negara Republik Indonesia diatur dalam Peraturan Lembaga." It governs the same object as RPP Pasal 190 ayat (3), consent as a route for transfer out of the jurisdiction, and it sits immediately after PP Pasal 173, the enacted consent article.

RPP Pasal 101 ayat (1) survives verbatim in substance at PP Pasal 1 angka 23, so striking it out states the law falsely. The change is one of legal form: an operative ayat inside the retention article became a defined term governing the whole instrument, which is why this is recast and not a plain relocation.

Per the panel rule I do not add PP Pasal 1, which is the definitions article and far over the length limit; the move is stated in the analysis instead and the add lists stay empty. The finding's own claim about Pasal 75 stands, so the rewrite keeps it and corrects only the deletion reading.

Overreach on huruf j, and internally inconsistent. PP Pasal 75 ayat (2) huruf j reads 'dasar hukum pengaturan, jika Masa Retensi karena kewajiban hukum sesuai dengan ketentuan peraturan perundang-undangan'. The requirement is conditional on the retention period arising from a legal obligation.

Case 1 and case 3 are the same move at clause and article level: RPP Pasal 13 huruf a survives at PP Pasal 70, converted from a controller duty into a subject right. The headline claim that all six duty articles disappear therefore reads as a deletion that did not happen, which is why this is recast rather than relocation, and PP Pasal 70 is added because it is a single short sentence.

Case 2 is coincidental: RPP Pasal 14 huruf b imposes compliance with cross border transfer criteria, while PP Pasal 174 is the standard ketentuan lebih lanjut diatur dalam Peraturan Lembaga deferral aimed at the consent mechanism, so the shared vocabulary is a drafting formula and Pasal 174 is not added.

Analysis contradicts the quoted draft text. It says the conduct is now on the subject's initiative "rather than the controller's own motion". RPP Pasal 13 huruf a reads memfasilitasi Subjek Data Pribadi untuk melengkapi, memperbarui, dan/atau memperbaiki, so the draft duty was already discharged on the subject acting. There was no own-motion duty to lose.

The flagged clause is RPP Pasal 16 ayat (2), not the requester rule. It survives verbatim as PP Pasal 1 angka 6, so showing it struck through as deleted is false. PP Pasal 1 is the definitions article and is far past the length bar, so it stays out of the panel and the survival is stated in the analysis instead.

The finding's headline holds on its own limb: PP Pasal 10 lists only the three parties and carries no deeming rule for a party requesting data, so RPP Pasal 16 ayat (3) has no enacted counterpart in the text before me.

Relocation overreach in what_changed. "it moved into the definitions at PP Pasal 1 angka 6" asserts a movement the brief cannot establish, because RPP Pasal 1 is not reproduced anywhere in it. If the draft's own definitions article already carried the same definition, nothing moved and RPP Pasal 16 ayat (2) was an in-place restatement that was simply not repeated. All the brief supports is that the substance survives in PP Pasal 1 angka 6.; Textual inaccuracy in the analysis.

The brief does not settle whether PP Pasal 165 ayat (4) descends from RPP Pasal 185 ayat (4). Two things are missing. First, the enacted counterpart of RPP Pasal 185, the PP article on Pelindungan Data Pribadi yang memadai dan bersifat mengikat, is not in the brief, and the finding's own analysis places related enacted material at Pasal 171.

If that article carries its own non-derogation clause, RPP Pasal 185 ayat (4) already has a successor there and PP Pasal 165 ayat (4) is a fresh provision, not a relocation. Second, PP Pasal 165 ayat (4) is transcribed in broken word order and cut off mid clause at ayat (1), ayat (2), dan, so neither the identity of the Lembaga nor the scope of the power can be read from the text supplied.

Same shared phrase, different chapters.

Same shared phrase, different chapters.

Same shared phrase, different chapters.

RPP Pasal 33 answers to PP Pasal 18 rather than the PP Pasal 17 the finding names. Another off by one.

No verdict recorded for this case.

No verdict recorded for this case.

RPP Pasal 179 answers to PP Pasal 157, not the PP Pasal 158 the finding names.

RPP Pasal 154 is controller accountability, PP Pasal 141 is processor accountability. The two are drafted in parallel, which is what the match is picking up.

Two different deferral clauses, one on impact assessment and one on adequacy.

PP Pasal 80 ends processing; the finding is about minimisation.

PP Pasal 36 is the consent evidence duty, unrelated to processor accountability.

The retention period definition was not dropped. It moved into the definitions article, PP Pasal 1 angka 23, which is where the enacted text puts defined terms. Adding the whole of Pasal 1 to the panel would drown the slide, so this belongs in the analysis rather than the article list.

The authority's power to assess transfer conditions is in both texts. This is the same provision that produced my earlier false claim about PP Pasal 167 having no draft twin, so it is worth naming RPP Pasal 185 in the finding and closing that question on the page.

The destruction undertaking is not gone. It sits at PP Pasal 133 huruf g, moved out of the agreement and into the notice to the subject, and recast from a direct undertaking into a statement that the old controller will destroy the data once the corporate action closes. The finding's headline, that the agreement no longer must cover destruction, is true only of the agreement and reads as a deletion. It needs rewording.

Both are the deferral formula that ends a section. The draft defers transfer implementation generally, PP Pasal 174 defers the consent route specifically, so they are not the same rule.

The deferral formula again. Binding corporate rules and binding adequate protection are different objects.

PP Pasal 55 governs legitimate interests for public bodies, a different basis from the public task provision the finding is about. The match runs on shared vocabulary.

PP Pasal 48 is the deferral clause attached to vital interests, not the basis itself.

Same shared vocabulary as the public task case above.

No verdict recorded for this case.

No verdict recorded for this case.

The draft item is a compliance duty, PP Pasal 174 is a deferral clause.

No verdict recorded for this case.

The definition of the data subject moved into PP Pasal 1 angka 6 with the other defined terms. The finding is about the requester rule, which is a different limb, so the headline stands; the definition should be noted, not added to the panel.

Both mention transfer out of Indonesian jurisdiction, one as a scope item and one as a compliance duty. Whether the scope list genuinely absorbed the duty is a reading I would rather you made.

The whole-article test is matching on the shared 3 x 24 jam deadline formula. PP Pasal 92 is the withdrawal of consent clock, not the correction clock.

The same 3 x 24 jam formula.

The same 3 x 24 jam formula.

The same 3 x 24 jam formula.

PP Pasal 108 assesses the compensation request; RPP Pasal 118 sets up the channel for making one. Related but not obviously the same provision, and the finding is about where a refused claim goes next. Your call whether RPP Pasal 118 belongs in the panel.

PP Pasal 108 assesses the compensation request; RPP Pasal 118 sets up the channel for making one. Related but not obviously the same provision, and the finding is about where a refused claim goes next. Your call whether RPP Pasal 118 belongs in the panel.

The same 3 x 24 jam formula.

The same 3 x 24 jam formula.

RPP Pasal 38 answers to PP Pasal 20, one article before the PP Pasal 21 the finding names. This is the offset you described.