DATA GOVERNANCE FOR ARTIFICIAL INTELLIGENCE IMPLEMENTATION IN THE FINANCIAL SECTOR: AN INDONESIAN PERSPECTIVE

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Published Sep 30, 2025
https://doi.org/10.21098/jcli.v4i3.430


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Vol. 4 No. 3 (2025)

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Regina Damaris
Assegaf Hamzah & Partners
https://orcid.org/0009-0006-5927-6361
Sinta Dewi Rosadi
Universitas Padjadjaran
https://orcid.org/0000-0003-4733-8810
I Made Diyosena Bratadana
Assegaf Hamzah & Partners
https://orcid.org/0009-0008-3587-2227

Abstract

The fast-evolving landscape of Artificial Intelligence (AI) is transforming industries worldwide, including Indonesia’s financial sector. While AI presents immense opportunities for innovation and efficiency, it also poses complex challenges in data governance. This paper explores the need for Indonesia to establish a comprehensive and forward-thinking data governance framework tailored to AI implementation in the financial sector. Using a literature review method and drawing on global and local regulatory developments, the paper outlines key principles for AI-related data governance, including transparency, accountability, specificity, enforceability, and adaptability. By reimagining its approach to data governance, Indonesia can mitigate the risks of data misuse, enhance personal data protection, and foster an environment conducive to responsible AI innovation. The research addresses the foregoing issues by offering a conceptual foundation for policymakers, regulators, and financial institutions in Indonesia to develop better rules and practices for managing AI-related data to strengthen Indonesia’s technological sovereignty, particularly in the financial sector. The study finds that Indonesia’s current data governance framework in the financial sector is not yet optimal for supporting AI implementation. Indonesia’s data governance framework requires adjustments in key areas, namely specificity, enforceability, and adaptability, while also promoting stronger cooperation among stakeholders.

Keywords: artificial intelligence, data governance, AI governance, financial sector, technology regulation

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Author Biographies

Regina Damaris, Assegaf Hamzah & Partners

Regina Damaris is an associate at Assegaf Hamzah & Partners law firm, specializing in technology, media, and telecommunications (TMT) law. She has extensive experience advising major technology companies, financial institutions, and government agencies on complex regulatory and transactional matters. Her professional work includes assisting Indonesia’s largest technology company, GoTo, in its strategic alliance with ByteDance, supporting state-owned enterprises in drafting regulations for Indonesia’s digital government initiative (INA Digital), and advising multinational corporations on personal data protection compliance, IT contracts, and cryptocurrency licensing.

Beyond her legal practice, Regina has contributed to academic and policy discourse through research and publications. She has co-authored articles published in LexisNexis and Lexology on cybersecurity and financial regulations and has authored an op-ed for Indonesia's leading newspaper, The Jakarta Post, on the country’s online child protection laws. She has also contributed to research for the Carnegie Endowment for International Peace and Yale Law School’s Information Society Project, assisting Prof. Dr. Sinta Dewi Rosadi, S.H., LL.M., with studies on digital sovereignty and AI-driven misinformation in elections.

Additionally, Regina is an active member of Indonesia’s technology law community. She has participated in conferences and discussions on key technology law issues and has spoken on privacy and digital law at various events. She is a member of key professional associations in Indonesia’s data protection and technology law sectors, including the Association of Data Protection Practitioners of Indonesia (Asosiasi Praktisi Pelindungan Data Indonesia) and the Association of Technology and Information Legal Consultants of Indonesia (Asosiasi Konsultan Hukum Teknologi dan Informasi). Expanding her engagement beyond national boundaries, she is also a member of the Digital Communication Network (DCN) Global Association, which addresses critical global technology issues, such as the rise of misinformation during election seasons worldwide.

Sinta Dewi Rosadi, Universitas Padjadjaran

Prof. Dr. Sinta Dewi Rosadi, S.H., LL.M., has been a lecturer at the Faculty of Law, Universitas Padjadjaran since 1991 until the present. She teaches in the fields of Technology and Information Law, E-Commerce Law, Privacy Data Law in the Digital Era, International Trade Law, and International Contract Law at the Faculty of Law, Universitas Padjadjaran, from 1991 until now. She has also been teaching Cyber Law at the Faculty of Law, Universitas Parahyangan Bandung (Undergraduate Program) since 2019 and at Sekolah Tinggi Hukum Bandung (Master's Program) from 2016 to 2019.

Sinta Dewi completed her Bachelor's degree at the Faculty of Law, Universitas Padjadjaran, specializing in International Law, and graduated in 1987. She pursued her Master's degree at Washington College of Law, Washington D.C., USA, specializing in International Legal Studies, and graduated in 1998. She obtained her Doctoral degree from the Postgraduate Program at Universitas Padjadjaran, specializing in Technology, Information, and Communication Law, in 2009. Her dissertation was titled "Perlindungan Informasi Pribadi dalam E-Commerce”.

From 2014 to 2021, Sinta Dewi served as the Head of the Cyber Law Study Center and is currently the Head of the Department of Technology, Information, Communication, and Intellectual Property Law at the Faculty of Law, Universitas Padjadjaran. Since 2000, she has specialized in Cyber Law, E-Commerce Law, Telecommunications Law, and Personal Data Protection Law. Currently, she teaches Cyber Law at the Faculty of Law at Universitas Padjadjaran, Universitas Parahyangan, and Sekolah Tinggi Hukum Bandung. Beyond formal education, Sinta Dewi has also pursued several non-degree programs, including a Summer Course on American Legal Studies at the Faculty of Law, University of Wisconsin, in 1996. She then participated in the Training on Economic Law at the Faculty of Law, Harvard University, in 1997. In 2008, she joined the Visiting Professor Program at the Faculty of Law, University of Wisconsin, and in 2010, she took part in the Visiting Researcher Program at the Faculty of Law, University of New South Wales, Sydney. In 2019, she attended the Summer Course on Privacy & Policy at the Faculty of Law, University of Amsterdam, Netherlands. As a member of the Carnegie Endowment for International Peace, she contributed a paper on "Content Moderation and Digital Platform Liability," which was presented at a meeting in Brussels in 2022. Additionally, she is a member of the Majority World Initiative (MWI) Information Society Project at Yale Law School, USA, where she authored a paper titled "Artificial Intelligence: The Use of AI and Social Media for 'Black Campaigns' in the 2024 General Elections in Indonesia—A Review of Indonesian Laws on Black Campaigns”.

Sinta has also authored four books on personal data and published various articles in both national and international journals. She has contributed to the government, particularly the Ministry of Communication and Informatics, in drafting bills and academic papers for the Electronic Information and Transactions Law, the Public Information Disclosure Law, the Telecommunications Bill, the Convergence Bill, and the Personal Data Protection Bill. She also holds a certification from the European Institute for Privacy, Audit, Compliance & Certification (EIPACC). From 2012 to 2021, she served as the Head of the Cyber Law Centre (CLC) and is currently the Head of the Department of Technology, Information, Communication, and Intellectual Property Law at the Faculty of Law, Universitas Padjadjaran.

I Made Diyosena Bratadana, Assegaf Hamzah & Partners

Diyo is an Associate at Assegaf Hamzah & Partners, where he has been practicing since 2023. He earned his Bachelor of Laws (LL.B.) from the University of Indonesia in 2022. At Assegaf Hamzah & Partners, Diyo specializes in the Technology, Media, and Telecommunications (TMT) sector, providing legal advisory and regulatory compliance services to clients in dynamic and rapidly evolving industries. His expertise extends to personal data protection, a field in which he has developed a strong academic and professional foundation. His interest in this area was reflected in his undergraduate thesis, which examined the implementation of personal data protection principles for non-fungible tokens (NFTs) in blockchain technology.

How to Cite
Damaris, R., Rosadi, S. D., & Bratadana, I. M. D. (2025). DATA GOVERNANCE FOR ARTIFICIAL INTELLIGENCE IMPLEMENTATION IN THE FINANCIAL SECTOR: AN INDONESIAN PERSPECTIVE. Journal of Central Banking Law and Institutions, 4(3), 445–472. https://doi.org/10.21098/jcli.v4i3.430

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