<![CDATA[The rapid growth of digital assets has triggered legal conflicts between post-mortem privacy rights and the proprietary rights of heirs. This study aims to analyze the legal certainty of personal data protection after death concerning heirs’ access to social media accounts in Indonesia by comparing it with the legal systems of Germany and France. This study employs normative legal research using statutory, comparative, and conceptual approaches. The study examines primary, secondary, and tertiary legal materials relevant to personal data protection, digital assets, and inheritance law. The findings reveal legal gaps and regulatory disharmony between Indonesia’s Personal Data Protection Law and the Civil Code. The Personal Data Protection Law does not explicitly regulate the status of personal data after death or heirs’ authority to access digital accounts, while the Civil Code does not specifically recognize digital assets as objects of inheritance. Germany applies the principle of universal succession, whereas France provides mechanisms for determining the management of digital data after death. This study concludes that Indonesia requires legal reconstruction to regulate the status of digital assets, heirs’ authority, and limitations necessary to protect post-mortem privacy. The novelty of this study lies in proposing a legal harmonization model integrating Germany’s universal succession principle and France’s digital directives into the Indonesian legal system.]]>
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