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User Guidelines Law Enforcement Response System (“LERS”)

B.1. ABOUT

In Grab, public safety and data privacy is our first priority, Grab is committed to provide our best interest for Grab app’s users. As our commitment, Grab has developed a Law Enforcement Response System (“LERS”), a system to respond to information requests from law enforcement agencies. This System also supports Grab to control disclosure of personal data to law enforcement in accordance with applicable laws and Grab’s Privacy Notice.

LERS will only be used by law enforcement authorities and authorized government personnel to obtain evidence in connection with official legal proceedings. Grab does not accept any information requests except through the LERS portal. 

B.2. PREVAILING REGULATIONS & LEGAL PROCESS OVERVIEW

Grab is committed to support the criminal law enforcement procedure in accordance with relevant laws and regulations, including the Indonesia Criminal Procedure Code (“KUHAP”), Law No. 11 Year 2008 on Electronic Systems and Transactions (“ITE Law”), Law No. 27 Year 2022 on Personal Data Protection (“PDP Law”), Government Regulation Number 71 the Year 2019 (“GR 71/2019”), and Minister of Communications and Informatics Regulation Number 20 Year 2016 Concerning Personal Data Protection in Electronic System (“MOCI 20/2016”). Grab only gives access to its electronic data after we conduct a risk assessment and take into account the protection of privacy, secrecy, and integrity of the data.

Grab maintains users’ data in compliance with the personal data protection principle as also described in our Privacy Notice and Terms of Service. 

Grab will not release user personal data and information without a valid and binding legal request from authorized entities. Grab follows the applicable laws and regulations related to requests for electronic data and/or electronic information for law enforcement. Grab will also only disclose data under a lawful request from an investigator for specific criminal activities which are regulated in the prevailing laws and regulations and if the data is relevant to the case and need of the law enforcement procedures. 

Upon receiving a request for disclosure of personal data, legal process, or preservation request, Grab may only disclose the requested electronic data if doing so would be consistent with:

1. prevailing laws and regulations concerning criminal procedural law;
2. prevailing laws and regulations concerning personal data protection;
3. Grab’s core principles; and
4. Grab’s Privacy Notice.

Besides the above, for the purpose of seizure-related to an ongoing criminal investigation, the procedure consists of the below.

1. The authorized law enforcer must submit a lawful seizure court warrant signed by the Head of District Court for obtaining the personal data of Grab’s users.
2. Grab will only disclose the personal data relevant to the specific case, law enforcers cannot seize all records in LERs.  the entire Grab electronic system.
3. Grab will then notify the personal data owners regarding the seizure of its personal data.

B.3. DEFINITION 

In these LERS Guidelines, the following words shall have the meanings ascribed below:

1. “LERS Users” means any Law Enforcement and Ministries/Institutions who accesses or uses the LERS Portal; 
2. “Grab” or “We” or “Our” means a technology company that provides a platform for consumers to obtain or procure goods and services provided by partners. Grab’s role is merely as the data-controller for users’ personal data (consumer, driver, and merchant), which the data obtained on purposes of using the services from Grab;
3. “Consumer” or “User” means any end-user who accesses or uses the Platform to search for and obtain the Solutions;
4. “Driver” means users who have submitted the online or offline registration, and agree to be a driver-partner and/or delivery partner of Grab under this agreement;
5. “Merchant” means, users who have submitted the online or offline registration, and agree to be a merchant partner of Grab under this Agreement and other merchants commercial agreement (including General Terms and Conditions for Merchant stated at https://www.grab.com/id/en/merchant/food/merchant-terms/ (General Terms and Conditions for Merchant”);
6. “Solutions” means the following transportation, logistics, and/or rental services which are made available to Consumers through the Service, such as GrabTaxi, GrabCar, GrabBike, GrabFood, GrabMart, Grosir-Services, GrabFresh, GrabExpress, GrabWheels, Indonesia Bus Marketplace, Grab for Business, GrabHealth, GrabAds, GrabKitchen, GrabKios and GrabBeliBarang, GrabGift, and any other services which Grab may available from time to time; 
7. “Platform” means the relevant Grab technology platform, portal, or website that, when used in conjunction with the Application, enables Consumers to request or access Solutions;
8. “Application” means the relevant mobile application(s) made available for download by Grab (or its licensors) to Consumers and Partners respectively; 
9. “Partner” means the independent third parties (who are not affiliated with Grab) who provide the relevant Solutions to Consumers through the Service, including (a) Driver, Delivery Service Provider, (b) Merchant-partners such as GrabFood, and/or GrabMart, and (c) any other relevant goods and services providers;
10. “Service” means the linking of Consumers to Partners through the Application, Platform and/or Software;
11. “Privacy Notice” means Grab’s privacy notice accessible at: https://www.grab.com/id/en/privacy as amended from time to time; 
12. “Personal Data” is any information under the possession and control of Grab which can be used to identify Grab’s Users. This includes but is not limited to name, nationality, telephone number, bank, and credit card details, personal interests, email address, image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle, and insurance information.

B.4. HOW TO ACCESS LERS

B.4.1. Who 

Law Enforcement and Ministries/Institutions agents 

B.4.2. How To Create LERS Account 

When you create a LERS account Grab shall ask for some personal information, by providing accurate info, you can help keep your account secure and make our services more useful. You can create an account by following this page. 

If you have an issue while attempting to log in, please contact [email].

B.4.3.When

Anytime

B.4.4.Where?

You can access LERS from your browser by accessing the URL https://lers.grab.com 

B.5. HOW TO SUBMIT A REQUEST FOR INFORMATION 

When submitting a request to Grab, law enforcement should identify the specific account(s) implicated by the lawful request proven by an official letter from the authorized official. In submitting the request, law enforcement should provide a unique identifier associated with the account(s) which are including but are not limited to:

• name of the account; 
• email address;
• phone number;
• longitude and latitude coordinates;
• license plate; and/or
• other identifying information that is relevant.

Grab is also able to identify accounts that are relevant to a law enforcement investigation by searching for information related to a specific trip. In that case, information that can identify the trip should be provided, such as date, time, trip ID, pick up or drop off location, and/or other relevant information.

The aforementioned information shall then be submitted through the LERS Portal. Please note that Grab is unable to process overly broad, vague, or unduly burdensome requests. Kindly ensure that all requests are narrowly tailored to address a specific law enforcement need.

If law enforcement is requesting for information on behalf of a Grab user who has provided consent to do so, that user should instead be directed to obtain that information on their own from Grab. For more information on how the Grab user can do so, please refer to Grab’s Privacy Notice.

B.5.1 Legal Process for Request of Disclosure

Requests for data must then be supported by the legal process. Grab reserves the right to reject legal process for any reason, including requests that do not have a valid legal basis, are overbroad, vague, are not legitimized by authorized officials, or if Grab cannot verify the legitimacy of the request.

To be legitimate, the minimum elements for a request of disclosure submitted to Grab must generally:

• be addressed to the appropriate Grab entity;
• be issued in compliance with the prevailing laws and regulations;
• be issued by an appropriate and legitimate authority in their respective jurisdictions;
• be signed by an appropriate authority;
• be dated;
• provide a date to return the responsible materials; and
• specifically identify the targeted account(s), reasonably identified with the previously mentioned unique identifier, the type(s) of information within the account to be disclosed; and any applicable date range. 

B.5.2. Preservation Requests

Law enforcement may seek the preservation of account electronic data and/or electronic information for future investigation purposes. For this request, Grab may take steps to preserve any electronic data and/or electronic information in its possession regarding the relevant preservation request, A preservation is a one-time “snapshot” of the records or content in a Grab user’s account at the time we receive the preservation request; it is not ongoing, real-time preservation of those records. Grab reserves the right to reject preservation requests for any reason.

B.6. HOW TO GET YOUR INFORMATION REQUEST

After your account has been verified, you can start to create a request to LERS by referring to this page.

B.7. GRAB’S USER NOTIFICATION POLICY 

Grab may notify users concerning the request for data disclosure by the relevant law enforcement and government authorities unless (1) such notice is prohibited under the applicable law or (2) such notice would be otherwise counterproductive or impractical. 

As part of Grab’s investigation procedures, Grab may also choose to contact an individual identified in a law enforcement request in connection with any alleged safety incident. Grab will not initiate such contact if it reasonably believes, in its sole discretion, that such contact may:

• pose an immediate risk of serious injury or death to a member of the public; or 
• pervert the course of the criminal procedure process.

When submitting a request, law enforcement may ask that Grab not contact anyone associated with the request due to the foregoing reasons or other valid reasons as the case may be, including by way of providing an appropriate court order or process establishing that notification is prohibited, or by providing sufficient detail for Grab to determine if a request falls into one of the exceptions above..

B.8. THE AVAILABLE DATA UPON REQUEST 

B.8.1. Eyewitness Testimony Request 

Non-public information for witness testimony requests from Grab users will not be released to law enforcement except in response to appropriate legal processes, such as a court order for witness testimony or witness summons issued by the police or related institutions in the investigation no less than 3 days before the date of the examination is determined, as stipulated in Article 227 of the KUHAP.  

B.8.2. Other Related Data Request by Ministries/Institutions

Ministries/Institutions aside from law enforcement can also request specific data for monitoring purposes. Grab will assess the validity of this type of request on a case-by-case basis based on Grab’s discretion. The ministries/institutions which may request this type of data include but are not limited to the National Anti Narcotics Agency, National Intelligence Agency, Ministry of Transportation, Ministry of Tourism and Creative Economy, Ministry of Trade, and other relevant institutions. Ministries/Institutions may request data from Grab under the same procedures as mentioned above, however, Ministries/Institutions shall have the authority for the said request in accordance with the prevailing laws and regulations. 

The procedure for this request will still be conducted under the aforementioned procedure for law enforcement. The ministries/institutions will then comply with Privacy Policy.

Please note that data available for retrieval from LERS will be subject to requests in accordance with appropriate legal processes and for those which are reasonably able to retrieve. All Grab data will be subject to its retention policies in accordance with its Privacy Notice, and Grab does not retain any data for law enforcement purposes unless a valid preservation request has been received prior to its deletion and/or anonymisation.

B.9. THE INFORMATION AVAILABLE FROM GRAB 

This section describes the general categories of user personal data that may be available from Grab for LERS uses. Grab collects, uses, processes, and discloses user data in accordance with its Privacy Notice. Consequently, there are various legal processes required to access types of data that Grab would provide. 

B.9.1. Basic User’s Information

Basic User’s information is defined in Privacy Notice, which is the information provided by users voluntarily during the registration of a Grab account. If users have multiple relationships with Grab (for example if you use our Services across our various business verticals, or if you are both a driver-partner/delivery partner as well as a consumer to our Apps or on our other business verticals), Grab may combine all the collected information. 

Basic subscriber information maintained by Grab users may include:

• user profile information (i.e., name, email, phone number, address, profile photo, ID card number);
• usage information (i.e., date of account creation, and account status); and

• basic subscriber information may be obtained with a Letter of Assignment, Court Order, or pursuant to the emergency disclosure request. 

B.9.2. Device Information 

Device information contains hardware model and serial number, IP address, file names and versions, and advertising identifiers, or any information that may indicate device or app modification. This information can be obtained with a Letter of Assignment, Court order, or pursuant to the emergency disclosure request. 

B.9.3. Vehicle Information

Vehicle information includes license plate, vehicle model, and vehicle types vehicle insurance, vehicle registration, and vehicle registration (STNK). Vehicle information can be obtained with Witness Summons, Court Order, or pursuant to the emergency disclosure request. 

B.9.4. Billing Information

Billing information means information regarding particular transactions, like amount, date and time the transaction was made, and the payment instrument used. This billing information may only be obtained with a Letter of Assignment, Court Order, or pursuant to an emergency disclosure request.

B.9.5. Trip Information

Grab will disclose trip reports to users, which generally includes:

• an amount of charge/fee of the trip;
• the pick-up and drop-off locations; and
• information about the driver and users, including the name, rating, activity (depends on the services). 

Trip information may be obtained with a Court Order, Witness Summons, or pursuant to the emergency disclosure request.

B.9.6. Location Information

Grab obtains location information with GPS from users’ mobile devices to locate the position of a vehicle and to detect pick-up and drop-off locations. Location information can be obtained with Court Order, Witness Summons, or pursuant to the emergency disclosure request. 

B.9.7. Driver Profile Information

Grab may retain several following information about its drivers, such as vehicle information, basic subscriber information (i.e. name, date of birth, ID card number, driving license), and trip information.  Driver profile information may be obtained with Court Order, Witness Summons, or pursuant to the emergency disclosure request. 

B.9.8. Communication Information

Grab may retain communication information when users use Grab in-app communication features to interact with Grab agents, Grab users (drivers to riders), in-vehicle audio and/or video recording during a ride. This information may be obtained with Court Order and emergency disclosure request.

B.9.9. Customer Service Records

Grab may retain Customer Service Records including recordings of customer support calls and other customer support communications. This information may be obtained with Court Order. 

B.10. Other Business Record

Grab may retain Other Business Records such as: 

• referral programmes;
• our business partners, such as fleet partners, payment providers, ride-hailing partners, and transport partners;
• insurance and financial providers;
• credit bureaus, alternative credit scoring agencies, and any other credit reporting organizations;    
• publicly available sources of data;
• governmental sources of data;
• when our users add you as emergency contact; 
• when you use our in-app chat; and
• marketing services providers or partners. 

Thus, this other business record can be obtained with Court Order. 

B.11. Reimbursement

Grab does not seek any reimbursement for material and immaterial costs associated with responding to law enforcement requests for electronic data.

B.12. Updates

Grab may update the content of these guidelines periodically. Please refer to the guidelines before making any request.