<![CDATA[Restorative settlement of adult criminal cases in Indonesia ends proceedings without conviction, yet the governing instruments require identified register entry, fix no retention limit, and leave indexation to keep the record retrievable. Restorative justice separates reparation from reintegration, and termination tests only the first, so the publicity that follows records no restorative outcome and withholds the disapproval-withdrawal reintegration requires. It also operates as the functional equivalent of an additional penalty upon persons never convicted, exposure statute withholds from children but not adults. Because restrictions on data subject rights fall under a statutory reservation in Law No. 27 of 2022 and the 1945 Constitution, the question is one of form. It asks what a valid derogation requires, how the instruments qualify against delegation, and what redress remains. The study is doctrinal, resting on primary legal materials and documented practice. Three cumulative conditions govern derogation. Necessity is indexed to an active process and expires at closure, when retention keeps a basis, access a narrower one, publication none. The openness statute reaches the terminating instrument, not the identifiers of the person named in it. The instruments do not purport to derogate, and read as though they did satisfy neither branch of the statutory test, so a derogation resting on them is defective. Because redress requires the exposed person to disclose the identity at issue, defect and paralysis are one problem. The response lies in a statutory basis, anonymisation by default, closed retention allowing verification of eligibility, and determined access.]]>
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