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Two or three countries, side by side, one row per question. Pick up to 3.

Countries

ArmeniaChecked 18 August 2026

Yes, with paperworkWork: MediumEnforcement: Dormant

In one paragraph: Armenia lets personal data leave, but only to a country on an official approved list of 53 states, or with case-by-case permission from the privacy regulator. That regulator has had no boss since February 2026 and the largest fine it can impose is about 1,300 US dollars. The real constraints are elsewhere: government data sent to a foreign cloud must keep a backup copy inside Armenia, and banking and medical secrecy sit outside the privacy law entirely.
The catch: The approved-country list is worthless in three places. Government bodies must keep an in-country backup of anything they put in a cloud abroad. Bank, notarial, lawyer and insurance secrets are carved out of the privacy law and are governed by their own secrecy statutes, which list exhaustively who may see the data and do not mention foreign cloud providers. And leaking medical secrets is a crime that can put a named individual in prison, not just a fine on the company.
Does this apply to me?: Probably not, if you have nothing in Armenia. The privacy law describes who it covers by naming Armenian public bodies, companies and individuals who process personal data. It contains no clause saying it follows Armenians' data abroad, and no rule requiring a foreign company to appoint someone inside Armenia. There is no size or revenue threshold either, so a one-person Armenian business is caught exactly like a bank.Medium confidence
Can the data leave the country?: Yes, with paperwork. Armenia runs an approved-country list: if the destination is on it, you can send data with no permission from anyone. The list is real and populated — 53 countries, including all of the European Union, the United Kingdom, Canada, Japan, South Korea, Israel, Georgia and Russia. Sending data anywhere else needs written permission from the privacy regulator first, and that regulator currently has nobody in the chair. Three sectors override this entirely: government, banking-type secrets, and health.High confidence
What do I have to do to send it abroad?: The model is an approved list, and the list is full. Fifty-three countries were approved on 8 July 2024 and that decision has never been changed. If your destination is on it you need nothing — no standard contract, no filing, no fee. If it is not on it, you must write to the regulator before you send anything, attach the contract you plan to sign, and wait up to 30 days for a yes or a no.High confidence
Who enforces this — and are they actually working?: On paper, the Personal Data Protection Agency inside the Ministry of Justice. In practice, nobody right now: its head resigned with effect from 24 February 2026 and no replacement appointment has been published. In more than eleven years the agency has published exactly one general decision — the approved-country list. Two other regulators are genuinely working: the Central Bank supervises banks, payment firms, insurers and securities, and a brand-new Information Systems Regulatory Commission was appointed in March and April 2026 to police cybersecurity and state computer systems.Medium confidence
How long must I keep it, and when must I delete it?: The floor is five years for anything that proves your tax position. The ceiling is not a number — it is a principle: you must destroy or block personal data as soon as you no longer need it for the purpose you collected it for. Two hard clocks sit inside that principle. If someone withdraws consent you have ten working days to destroy their data, then three more working days to tell them you did. If you spot unlawful processing you have three working days to fix it or destroy the data.High confidence
What happens when something goes wrong?: Count three clocks. Under the privacy law, if data leaks out of your electronic systems you must immediately publish a public announcement about it and at the same time tell the Armenian police and the privacy regulator — there is no grace period and no threshold. If you run a system in a sector the state calls vital, you have 24 hours to tell the cybersecurity regulator, 72 hours to send an update, two days to warn the people affected, and one month to file a final report. Both sets of duties can bite at once.High confidence
What's the trap?: Five things that will ruin your week. One: a data leak must be announced publicly and reported to the police, not just to the regulator. Two: encryption is legally compulsory, not a best practice, and failing to use it is its own separate fine. Three: before you process biometric or sensitive data you must notify the regulator in advance and wait to be entered in its register. Four: to process a dead person's data you need the consent of all of their legal heirs. Five: a child is anyone under 16 here, not 13 and not 18.High confidence
What's about to change?: Armenia rewired its digital rulebook in December 2025 and the deadlines land through 2026, 2027 and 2028. Rules for cyber incidents and for state computer systems are already live. Detailed technical rules are due by January 2027, internal cybersecurity policies and risk assessments by July 2027, and security certificates for critical systems by January 2028. The change most likely to catch someone out is not a new law at all: the approved-country list can be rewritten by one official's signature.High confidence
Hardest industry wall: Government — «Ամպայինն առաջինը» քաղաքականության մշակման և ներդրման մասին ՀՀ կառավարության որոշում

IndonesiaChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Waking up

In one paragraph: Indonesia's general privacy law lets data leave if the destination protects it about as well as Indonesia does, or you use strong safeguards, or the person agrees. Money and health are walled off. Banks, payment firms, insurers and non-bank lenders must run their systems on Indonesian soil unless the financial regulator says otherwise, and medical records must sit with a local storage provider.
The catch: The relaxed headline is true only until you touch banking, payments, insurance and other non-bank finance, electronic medical records, or public-sector systems. In those areas the servers themselves must be in Indonesia, and moving them out needs a written permission that the banking regulator may take three months to grant. The general privacy watchdog looks quiet; the financial regulators are not.
Does this apply to me?: Yes. The privacy law follows the data, not the office. It covers any organisation, inside or outside Indonesia, whose handling of personal data has legal effects in Indonesia or affects people in Indonesia. There is no size or revenue cut-off to fall below. An organisation with no presence in the country is expected to name a representative in Indonesia, and any online service used by Indonesians is also expected to register with the digital ministry, which can order internet providers to block services that do not.Medium confidence
Can the data leave the country?: In general yes, with homework. You must be able to show the destination protects personal data at a level at least equal to Indonesia's, or put binding safeguards in place, or get the person's clear agreement. That general answer stops at the door of finance, health and government. Banks, payment providers, insurers and other non-bank financial firms must keep their systems in Indonesian data centres and back-up centres, and can only go offshore with written regulator permission. Electronic medical records must be stored with a provider that has storage facilities inside Indonesia.High confidence
What do I have to do to send it abroad?: There is no published list of approved countries and no official standard contract to sign. Under the general law you assess the destination yourself, write down why it is safe enough, and keep that evidence. In finance the model is completely different: you need a real permission from the regulator before the systems move, and the banking regulator allows itself up to three months to answer once your paperwork is complete.Medium confidence
Who enforces this — and are they actually working?: It depends which rule you break. The privacy law's own watchdog is the weak spot: the law says a supervisory body must be set up by the President, and we found no government source showing it is staffed and issuing decisions as of 18 August 2026. Day to day the digital ministry handles complaints, registration and blocking. The financial regulators are a different story — the Financial Services Authority and the central bank are plainly working, and the Authority issued new binding rules as recently as July 2026.Medium confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling and they collide. The hardest floor is health: a hospital or clinic must keep an electronic medical record for at least 25 years after the patient's last visit. Company and tax paperwork must also be kept for years. The ceiling comes from the privacy law, which says personal data must be erased once the purpose is finished, the retention period ends, or the person withdraws consent. Where they clash, the specific keeping rule wins, so a patient asking for deletion does not defeat the 25-year rule.High confidence
What happens when something goes wrong?: Count at least three clocks, and the privacy one is not the fastest. Under the privacy law you have 72 hours to tell the affected people and the regulator about a personal data breach. If you are a bank, you must send the financial regulator a first alert within 24 hours of learning about a serious technology incident, and a full incident report within five working days. Other financial firms, such as insurers and lenders, have five working days. Miss the 24-hour one and the fact that you met the 72-hour one will not help you.High confidence
What's the trap?: Five things that ruin weekends. (1) In finance the wall is a permission, not a contract — moving systems abroad needs a regulator licence and the banking regulator gives itself up to three months to decide, so cloud migrations must be planned around that. (2) In health your cloud provider must have storage facilities in Indonesia, and the Ministry of Health can demand access to the whole medical record. (3) The 25-year medical record rule beats a patient's deletion request. (4) The privacy law carries prison sentences, not just fines, so directors are personally exposed. (5) A foreign company with no office still needs a named representative in Indonesia, and a consumer service that is not registered with the digital ministry can be blocked at the internet level.Medium confidence
What's about to change?: One dated change is certain: from 1 September 2026 trading in digital financial assets, including crypto, runs under the financial regulator's new rulebook, so anyone in that business should re-check where its servers and records must sit. Two things are still pending as far as we could verify: the detailed implementing regulation under the privacy law, and the presidential decision setting up the privacy watchdog itself. Both could land without warning.Medium confidence
Hardest industry wall: Banking — Peraturan Otoritas Jasa Keuangan Nomor 11/POJK.03/2022 tentang Penyelenggaraan Teknologi Informasi oleh Bank Umum
Payments — Peraturan Bank Indonesia Nomor 23/6/PBI/2021 tentang Penyedia Jasa Pembayaran
Insurance — Peraturan Otoritas Jasa Keuangan Nomor 4/POJK.05/2021 tentang Penerapan Manajemen Risiko dalam Penggunaan Teknologi Informasi oleh Lembaga Jasa Keuangan Nonbank
Health and social care — Peraturan Menteri Kesehatan Nomor 24 Tahun 2022 tentang Rekam Medis
Government — Peraturan Pemerintah Nomor 71 Tahun 2019 tentang Penyelenggaraan Sistem dan Transaksi Elektronik
Mapping and location — Undang-Undang Nomor 4 Tahun 2011 tentang Informasi Geospasial

The eight framework questions answered for each selected country
Question	ArmeniaChecked 18 August 2026	IndonesiaChecked 18 August 2026
The three ratings	Yes, with paperwork Work: Medium Enforcement: Dormant	Depends on your industry Work: High Enforcement: Waking up
In one paragraph	Armenia lets personal data leave, but only to a country on an official approved list of 53 states, or with case-by-case permission from the privacy regulator. That regulator has had no boss since February 2026 and the largest fine it can impose is about 1,300 US dollars. The real constraints are elsewhere: government data sent to a foreign cloud must keep a backup copy inside Armenia, and banking and medical secrecy sit outside the privacy law entirely.	Indonesia's general privacy law lets data leave if the destination protects it about as well as Indonesia does, or you use strong safeguards, or the person agrees. Money and health are walled off. Banks, payment firms, insurers and non-bank lenders must run their systems on Indonesian soil unless the financial regulator says otherwise, and medical records must sit with a local storage provider.
The catch	The approved-country list is worthless in three places. Government bodies must keep an in-country backup of anything they put in a cloud abroad. Bank, notarial, lawyer and insurance secrets are carved out of the privacy law and are governed by their own secrecy statutes, which list exhaustively who may see the data and do not mention foreign cloud providers. And leaking medical secrets is a crime that can put a named individual in prison, not just a fine on the company.	The relaxed headline is true only until you touch banking, payments, insurance and other non-bank finance, electronic medical records, or public-sector systems. In those areas the servers themselves must be in Indonesia, and moving them out needs a written permission that the banking regulator may take three months to grant. The general privacy watchdog looks quiet; the financial regulators are not.
Does this apply to me?	Probably not, if you have nothing in Armenia. The privacy law describes who it covers by naming Armenian public bodies, companies and individuals who process personal data. It contains no clause saying it follows Armenians' data abroad, and no rule requiring a foreign company to appoint someone inside Armenia. There is no size or revenue threshold either, so a one-person Armenian business is caught exactly like a bank.Medium confidence	Yes. The privacy law follows the data, not the office. It covers any organisation, inside or outside Indonesia, whose handling of personal data has legal effects in Indonesia or affects people in Indonesia. There is no size or revenue cut-off to fall below. An organisation with no presence in the country is expected to name a representative in Indonesia, and any online service used by Indonesians is also expected to register with the digital ministry, which can order internet providers to block services that do not.Medium confidence
Can the data leave the country?	Yes, with paperwork. Armenia runs an approved-country list: if the destination is on it, you can send data with no permission from anyone. The list is real and populated — 53 countries, including all of the European Union, the United Kingdom, Canada, Japan, South Korea, Israel, Georgia and Russia. Sending data anywhere else needs written permission from the privacy regulator first, and that regulator currently has nobody in the chair. Three sectors override this entirely: government, banking-type secrets, and health.High confidence	In general yes, with homework. You must be able to show the destination protects personal data at a level at least equal to Indonesia's, or put binding safeguards in place, or get the person's clear agreement. That general answer stops at the door of finance, health and government. Banks, payment providers, insurers and other non-bank financial firms must keep their systems in Indonesian data centres and back-up centres, and can only go offshore with written regulator permission. Electronic medical records must be stored with a provider that has storage facilities inside Indonesia.High confidence
What do I have to do to send it abroad?	The model is an approved list, and the list is full. Fifty-three countries were approved on 8 July 2024 and that decision has never been changed. If your destination is on it you need nothing — no standard contract, no filing, no fee. If it is not on it, you must write to the regulator before you send anything, attach the contract you plan to sign, and wait up to 30 days for a yes or a no.High confidence	There is no published list of approved countries and no official standard contract to sign. Under the general law you assess the destination yourself, write down why it is safe enough, and keep that evidence. In finance the model is completely different: you need a real permission from the regulator before the systems move, and the banking regulator allows itself up to three months to answer once your paperwork is complete.Medium confidence
Who enforces this — and are they actually working?	On paper, the Personal Data Protection Agency inside the Ministry of Justice. In practice, nobody right now: its head resigned with effect from 24 February 2026 and no replacement appointment has been published. In more than eleven years the agency has published exactly one general decision — the approved-country list. Two other regulators are genuinely working: the Central Bank supervises banks, payment firms, insurers and securities, and a brand-new Information Systems Regulatory Commission was appointed in March and April 2026 to police cybersecurity and state computer systems.Medium confidence	It depends which rule you break. The privacy law's own watchdog is the weak spot: the law says a supervisory body must be set up by the President, and we found no government source showing it is staffed and issuing decisions as of 18 August 2026. Day to day the digital ministry handles complaints, registration and blocking. The financial regulators are a different story — the Financial Services Authority and the central bank are plainly working, and the Authority issued new binding rules as recently as July 2026.Medium confidence
How long must I keep it, and when must I delete it?	The floor is five years for anything that proves your tax position. The ceiling is not a number — it is a principle: you must destroy or block personal data as soon as you no longer need it for the purpose you collected it for. Two hard clocks sit inside that principle. If someone withdraws consent you have ten working days to destroy their data, then three more working days to tell them you did. If you spot unlawful processing you have three working days to fix it or destroy the data.High confidence	There is a floor and a ceiling and they collide. The hardest floor is health: a hospital or clinic must keep an electronic medical record for at least 25 years after the patient's last visit. Company and tax paperwork must also be kept for years. The ceiling comes from the privacy law, which says personal data must be erased once the purpose is finished, the retention period ends, or the person withdraws consent. Where they clash, the specific keeping rule wins, so a patient asking for deletion does not defeat the 25-year rule.High confidence
What happens when something goes wrong?	Count three clocks. Under the privacy law, if data leaks out of your electronic systems you must immediately publish a public announcement about it and at the same time tell the Armenian police and the privacy regulator — there is no grace period and no threshold. If you run a system in a sector the state calls vital, you have 24 hours to tell the cybersecurity regulator, 72 hours to send an update, two days to warn the people affected, and one month to file a final report. Both sets of duties can bite at once.High confidence	Count at least three clocks, and the privacy one is not the fastest. Under the privacy law you have 72 hours to tell the affected people and the regulator about a personal data breach. If you are a bank, you must send the financial regulator a first alert within 24 hours of learning about a serious technology incident, and a full incident report within five working days. Other financial firms, such as insurers and lenders, have five working days. Miss the 24-hour one and the fact that you met the 72-hour one will not help you.High confidence
What's the trap?	Five things that will ruin your week. One: a data leak must be announced publicly and reported to the police, not just to the regulator. Two: encryption is legally compulsory, not a best practice, and failing to use it is its own separate fine. Three: before you process biometric or sensitive data you must notify the regulator in advance and wait to be entered in its register. Four: to process a dead person's data you need the consent of all of their legal heirs. Five: a child is anyone under 16 here, not 13 and not 18.High confidence	Five things that ruin weekends. (1) In finance the wall is a permission, not a contract — moving systems abroad needs a regulator licence and the banking regulator gives itself up to three months to decide, so cloud migrations must be planned around that. (2) In health your cloud provider must have storage facilities in Indonesia, and the Ministry of Health can demand access to the whole medical record. (3) The 25-year medical record rule beats a patient's deletion request. (4) The privacy law carries prison sentences, not just fines, so directors are personally exposed. (5) A foreign company with no office still needs a named representative in Indonesia, and a consumer service that is not registered with the digital ministry can be blocked at the internet level.Medium confidence
What's about to change?	Armenia rewired its digital rulebook in December 2025 and the deadlines land through 2026, 2027 and 2028. Rules for cyber incidents and for state computer systems are already live. Detailed technical rules are due by January 2027, internal cybersecurity policies and risk assessments by July 2027, and security certificates for critical systems by January 2028. The change most likely to catch someone out is not a new law at all: the approved-country list can be rewritten by one official's signature.High confidence	One dated change is certain: from 1 September 2026 trading in digital financial assets, including crypto, runs under the financial regulator's new rulebook, so anyone in that business should re-check where its servers and records must sit. Two things are still pending as far as we could verify: the detailed implementing regulation under the privacy law, and the presidential decision setting up the privacy watchdog itself. Both could land without warning.Medium confidence
Hardest industry wall	Government — «Ամպայինն առաջինը» քաղաքականության մշակման և ներդրման մասին ՀՀ կառավարության որոշում	Banking — Peraturan Otoritas Jasa Keuangan Nomor 11/POJK.03/2022 tentang Penyelenggaraan Teknologi Informasi oleh Bank Umum Payments — Peraturan Bank Indonesia Nomor 23/6/PBI/2021 tentang Penyedia Jasa Pembayaran Insurance — Peraturan Otoritas Jasa Keuangan Nomor 4/POJK.05/2021 tentang Penerapan Manajemen Risiko dalam Penggunaan Teknologi Informasi oleh Lembaga Jasa Keuangan Nonbank Health and social care — Peraturan Menteri Kesehatan Nomor 24 Tahun 2022 tentang Rekam Medis Government — Peraturan Pemerintah Nomor 71 Tahun 2019 tentang Penyelenggaraan Sistem dan Transaksi Elektronik Mapping and location — Undang-Undang Nomor 4 Tahun 2011 tentang Informasi Geospasial