Pseudonymization of Personal Data of Crypto Assets Users: Issues of Legal Regulation in Indonesia

Objective: to analyze the possibility of providing legal protection for pseudonymized personal data of crypto assets users in the legal system of Indonesia. Methods: the work uses a comprehensive legal analysis based on the study of the current regulatory legal acts of Indonesia in the field of personal data protection. The research was carried out using legislative, conceptual and comparative methodological approaches, including an analysis of the Indonesian Law on Personal Data Protection, the EU General Regulation on Personal Data Protection, and the British Data Protection Act. Results: it was established that pseudonymization of crypto assets user data in Indonesia is feasible from a legal point of view; however, the existing legislation contains significant gaps. The current Indonesian Personal Data Protection Law does not recognize pseudonymized data as a separate category of personal data subject to legal protection. The authors point out the problems with the implementation of the rule for controlling transfers of crypto assets by physical traders. As additional information for the re-identification of pseudonymized data is not stored separately, it increases the risks of privacy violations. Scientific novelty: the authors provide a comprehensive analysis of the legal mechanisms for protecting pseudonymized data in the context of cryptocurrency transactions. A conceptual model is proposed for improving national legislation on personal data protection. It implies including pseudonymized data as a separate category of protected information. Recommendations are given, which establish criteria for the legitimate re-identification of pseudonymized data to ensure legal certainty in the field of protecting crypto assets users. Practical significance: the research results can serve as a theoretical and methodological basis for reforming the Indonesian Law on Personal Data Protection and creating an effective legal mechanism for protecting crypto assets users. The proposed amendments to Article 4 of the said Law will make it possible to include pseudonymized data in the list of protected categories of personal data, which will provide legal certainty for participants in the cryptocurrency market and increase the level of their personal data protection in the digital economy.