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All Journal Lex Scientia Law Review JILS (Journal of Indonesian Legal Studies)
Zerara, Aouatef
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Law, Crime, Criminology & Criminal Justice

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Toward an Effective Legal Framework for Digital Health E-Commerce: Insights from the UAE and Indonesia Benseghir, Mourad; Maamar Bentria; Zerara, Aouatef; Bendriss, Halima; Berrahlia, Badreddine
Lex Scientia Law Review Vol. 9 No. 2 (2025): November, 2025: Law, Policy, and Governance in Contemporary Socio-Economic Tran
Publisher : Universitas Negeri Semarang

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.15294/lslr.v9i2.12152

Abstract

This study compares the regulatory frameworks of the United Arab Emirates (UAE) and Indonesia governing the online provision and sale of health-related technologies. In technology-driven healthcare, data privacy and the security of digital transactions are central concerns. Employing a normative juridical approach, the research analyses applicable legislation, regulatory instruments, and scholarly literature in both jurisdictions. The findings indicate that the UAE has developed a relatively robust and comprehensive framework, particularly in relation to data protection and the security of digital health infrastructure, supported by detailed and stringent rules. By contrast, Indonesia’s regulatory framework remains less effective in practice, hindered by limited public awareness of data security, uneven enforcement, and implementation challenges at the local and regional levels. The study underscores the key differences between the two systems and highlights the need, especially in Indonesia, for clearer, more enforceable rules on health-related online transactions and stronger safeguards for personal health data.
Legal Aspects of Patient Data Governance in Digital Health: A Comparative Analytical Study of UAE and Indonesian Legislation Benseghir, Mourad; Zerara, Aouatef; Bentria, Maamar; Bendriss, Halima; Muhtar, Mohamad Hidayat
Journal of Indonesian Legal Studies Vol. 10 No. 2 (2025): Legal Responses to Technological Innovation and Governance Challenges in Indon
Publisher : Universitas Negeri Semarang

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.15294/jils.v10i2.10025

Abstract

This study provides a comparative legal analysis of the United Arab Emirates (UAE) and Indonesia regarding the regulation of digital health technologies, particularly electronic medical records (EMR) and artificial intelligence (AI). It examines core legal dimensions including data security, patient consent, monitoring mechanisms, and data ownership. Although both countries have adopted ambitious digital health strategies, the UAE has developed a more comprehensive and integrated regulatory framework through Federal Law No. 2 of 2019 on the Use of Information and Communication Technology in Health Fields and the Personal Data Protection Law No. 45 of 2021. These instruments ensure stricter data protection, structured access control, encryption standards, and regular audit mechanisms. In contrast, Indonesia, despite the enactment of Minister of Health Regulation No. 24 of 2022 and Law No. 27 of 2022 on Personal Data Protection, still faces challenges in enforcement, interoperability, and accountability. The findings highlight the need for Indonesia to strengthen its legal and institutional infrastructure to ensure compliance, enhance data privacy, and promote patient trust in digital health systems. Drawing lessons from the UAE experience, the study proposes policy reforms aimed at aligning Indonesia’s legal framework with international standards and fostering a secure, ethical, and innovation-oriented digital health environment.
Co-Authors Bendriss, Halima Benseghir, Mourad Bentria, Maamar Berrahlia, Badreddine Maamar Bentria Mohamad Hidayat Muhtar