Electronic System (Sistem Elektronik) under Permenkes 24/2022 and PP 71/2019

Under Minister of Health Regulation (Permenkes) Number 24 of 2022 on Medical Records. An Electronic System (Sistem Elektronik) is a series of electronic devices. Furthermore, Procedures functioning to prepare, collect, process, analyze, store, display, announce, transmit, and/or disseminate electronic information (Article 1(7)). Electronic medical record applications in clinics and hospitals fall within this definition.

Where the Term Is Regulated

The exact same formulation appears in the Electronic Information and Transactions Law (UU 11/2008 as amended by UU 19/2016. Furthermore, UU 1/2024, Article 1(5)), Government Regulation (PP) Number 71 of 2019 (Article 1(1)), and Permenkes 24/2022.

Why It Matters in Practice

PP 71/2019 Article 3(1) requires operators to run Electronic Systems reliably, securely, and responsibly. For electronic medical records, Permenkes 24/2022 adds specific duties:

• The system must have compatibility and/or interoperability capabilities (Article 10(1)).
• The health facility or its system operator must register the system with the Ministry of Health. Submitting the system name, documentation, functions, data storage location, variables. Furthermore, Metadata, and list of user facilities (Article 12).
• Systems developed through cooperation with an Electronic System Operator require that operator to be registered in the health sector with the ministry handling communications and informatics (Article 9(1), (3)).

Related terms: Electronic System Operator (Article 1(8)), Compatibility (Article 10(2)), and Interoperability (Article 10(3)).

Legal basis: Permenkes Number 24 of 2022 Articles 1(7)–(8), 9, 10, and 12. PP Number 71 of 2019 Articles 1(1) and 3(1). Law Number 11 of 2008 as amended by Law 19/2016 and Law 1/2024 Article 1(5).