Recommendations
The scope of personal data processed regarding the Law on Dwelling is in compliance with the purpose of the processing but the practice shows that on the Information Boards in the buildings a wider scope of data has been published than it should. In the Law on Dwelling there is no provision that stipulates publishing of data (name and surname) of tenants who paid for the maintenance and this is not in line with the LPDP.
Keeping period of personal data is envisaged only for the video surveillance – 30 days. Keeping periods should be precised for every personal data collection.
Although it is stipulated that the Law on Dwelling should be in compliance with the LPDP, there is no provision for the obligation for adopting documentation for technical and organizational measures for personal data protection.