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ArgentinaChecked 18 August 2026
Yes, with paperworkWork: MediumEnforcement: Active
In one paragraph
Argentina lets personal data leave the country, but only on paper terms it sets. You either send it to a country the regulator has approved, or you sign the regulator's own model contract with the receiver. No industry has to keep data inside Argentina. Fines are tiny in dollars, but the regulator can order a database shut down, and some misuse is a crime.
The catch
There is no data-residency wall in Argentina, but four sector rules still catch people out. Banks and payment firms must run their technology and security management from inside Argentina, must tell the banking supervisor before they outsource, and must report a cyber incident within one hour. Government bodies must have a working backup data centre by late 2026. And nobody may publish a map showing Argentine territory without the national mapping agency's prior approval.
Does this apply to me?
The main privacy law is Ley 25.326, passed in 2000. It covers personal data held in any file or database in Argentina, public or private. There is no size threshold, no revenue threshold, and no duty to appoint a local representative. The law does not clearly say it reaches a foreign company with no presence in Argentina, and in practice the regulator has acted against local subsidiaries of global firms rather than against foreign entities directly.High confidence
Can the data leave the country?
Yes, with paperwork. The rule is that personal data may not go to a country that does not protect it well enough. The regulator publishes a list of countries it accepts, and for everywhere else you sign its model contract with the receiver. We looked for industries that must keep data inside Argentina - banking, payments, insurance, securities, health, telecoms, government cloud and mapping - and found none as of 18 August 2026.High confidence
What do I have to do to send it abroad?
The model is an approved-destinations list, and it is populated today with about a dozen places, including the whole European Union. If your destination is not on it, use the regulator's published model contract - two versions, one for handing data to another company that decides how to use it and one for a supplier processing it for you. Using the published wording needs no permission. If you change the wording, you must file the contract with the regulator within 30 days of signing.High confidence
Who enforces this — and are they actually working?
The Agency for Access to Public Information, known by its Spanish initials AAIP, enforces both privacy and freedom of information. It is real and working: it has a named head, it publishes a register of final penalties that was updated on 3 July 2026, it opened a public investigation into debt-collection calls in April 2026, and it chaired an international data-protection committee in July 2026. Its 244 final penalties are mostly small, and more than half are for calling people on the do-not-call list.High confidence
How long must I keep it, and when must I delete it?
Argentina has strong floors and one hard ceiling. Anti-money-laundering rules make banks, insurers, crypto firms, accountants and estate agents keep transaction records and customer files for at least ten years. Clinical records must be kept ten years from the last entry. Banks must keep audit and accounting support data six years and produce it immediately on demand. The ceiling: credit-reporting data may only show the last five years, dropping to two years once the debt is paid.High confidence
What happens when something goes wrong?
There is no general duty to report a data breach in Argentina, checked on 18 August 2026 - the privacy law has no deadline and the regulator's security rules are recommendations, not commands. Finance is the exception and the clock is brutal: banks and registered payment firms must tell the banking supervisor within one hour of an incident happening or being spotted, keep sending updates, and file a closing report within five days.High confidence
What's the trap?
Five things bite people. Answer times are very short: ten days for an access request and five working days to correct or delete. The maximum fine is one hundred thousand pesos, about seventy US dollars, so the real risk is a shutdown order or a criminal case, not the fine. Databases still have to be registered. Publishing a map of Argentina needs government approval first. And a bank cannot run its technology and security management from abroad.High confidence
What's about to change?
Nothing is scheduled to replace the privacy law. A reform bill went to Congress in 2023 and never became law; the regulator is still campaigning for a new one. The dated thing to watch is government cybersecurity: public bodies have about 180 days from 13 May 2026 to have contingency plans and a working alternative data centre, which lands around November 2026, and a new national cybersecurity centre started issuing rules in 2026.Medium confidence
Hardest industry wall
None found.
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