ABSTRACT
Law No. 27 of 2022 on Personal Data Protection is considered insufficient for safeguarding personal data, particularly against potential misuse by data controllers outside Indonesian jurisdiction. This article adopts a qualitative and comparative approach, examining case studies and policy aspects to identify differences and challenges in Indonesia and Singapore's cybersecurity and personal data protection frameworks. Comparative analysis demonstrates how both countries address cross-border data protection issues. The findings show that Singapore's framework offers a more transparent and secure model than Indonesia's. Consequently, this study highlights the need to strengthen Indonesia's legal framework to foster a sustainable digital environment that aligns with Sustainable Development Goals (SDG) 9 and 16.
