Compare countries

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

Countries

AustraliaChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Australia has no general rule that data must stay in the country. You may send personal information anywhere, and no destination is banned. The catch is that you stay legally responsible for whatever your overseas supplier does with it. Small businesses under A$3 million turnover are exempt from the main privacy law. Specific industries are far stricter, and one of them carries a prison sentence.
The catch: The relaxed headline stops the moment you touch six areas. National electronic health records may not leave Australia at all, and taking them offshore is a crime punishable by five years in prison. Banks and insurers must tell the banking regulator before any offshore arrangement. Open banking data, critical infrastructure data, Australian Government hosting and Queensland state government data each have their own rules. Check your sector before you believe the headline.
Does this apply to me?: Yes, it reaches you even with no office in Australia. The national privacy law applies to any organisation that carries on business in Australia, whether or not the data is collected or stored here. But Australia has something most countries do not: a real size threshold you can fall below. A business with annual turnover of A$3 million (about US$2 million) or less is generally exempt. That exemption has big holes: it does not apply if you provide a health service, if you buy or sell personal information, or if you supply services under a federal government contract. No local representative and no registration are required.High confidence
Can the data leave the country?: In general, yes. Australia has no national law saying personal data must be kept in the country, and no country is blacklisted. You can pick any cloud region you like. What you cannot do is hand off the risk: if your overseas supplier does something with the data that would break Australian rules, the law treats that as your own breach. The hard walls are industry by industry, and the health one is absolute.High confidence
What do I have to do to send it abroad?: Before data leaves, you must take reasonable steps to make sure the overseas recipient will handle it the Australian way. In practice that means a contract with the right promises in it. There is no government form to file, no approval to wait for, and no list of approved countries to check. A power to approve countries was switched on in December 2024, but as of today the government has not named a single one. The alternative routes are narrow: you can rely on the recipient already being covered by a substantially similar law, or on the person's informed consent after you warn them you will no longer be responsible.High confidence
Who enforces this — and are they actually working?: The Office of the Australian Information Commissioner. It is staffed, it has a sitting Privacy Commissioner, and it is issuing decisions. In October 2025 the Federal Court ordered a pathology company to pay A$5.8 million (about US$3.8 million), the first court penalty in the law's history. The regulator sued Optus in August 2025, settled with Meta for A$50 million in December 2024, and in June 2026 alone published formal findings against Optus, American Express and two health providers. Banking, cyber security, online safety and open banking each have their own separate regulator, and all of them are working.High confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling and they pull in opposite directions. The clearest floor is telecoms: phone and internet providers must keep call and connection records for two years, and must encrypt them. The general ceiling has no number attached — you must destroy or de-identify personal information once you genuinely no longer need it. Two ceilings are sharp. A social media platform must destroy age-check information as soon as it has finished using it. A digital identity provider must destroy a face or fingerprint scan immediately after the identity check is complete.High confidence
What happens when something goes wrong?: Count four clocks, because they run at different speeds. If you pay a ransom and your Australian turnover is above A$3 million (about US$2 million), you have 72 hours to report the payment to the government. If you run critical infrastructure, you have 12 hours for an attack that seriously hits availability, and 72 hours for a lesser one. If you are a bank, insurer or superannuation fund, you have 72 hours for a security incident and only 24 hours if a critical service goes down beyond tolerance. For an ordinary personal data breach you get up to 30 days to assess whether it is serious, then you must tell the regulator and the affected people as soon as you practically can. There is no fixed hour count for that last one, which is the part people get wrong.High confidence
What's the trap?: Five things that will cost you a weekend. First, moving national electronic health record data offshore is a crime, not a fine: up to five years in prison. Second, you never stop owning your supplier's mistakes — a major bank had to get a special ruling from the Privacy Commissioner just to keep processing international money transfers. Third, since December 2025 social media platforms must keep under-16s off the service and then destroy the age-check data they collected. Fourth, Queensland's rule for state government data is stricter than the national one and is hidden in section 33 of the Act, not in the numbered principles — the principle numbered 8 says there is no equivalent. Fifth, the value of a penalty unit rose to A$364 (about US$240) on 1 July 2026, so every fine figure you looked up before then is now understated.High confidence
What's about to change?: One date dominates: 10 December 2026. On that day privacy policies must start explaining computer-made decisions that significantly affect people, and the new Children's Online Privacy Code must be finalised and registered. The draft of that code was out for public comment from 31 March to 5 June 2026. Further out, the tougher critical infrastructure duties made in June 2026 start biting from mid-2027 and mid-2028 as their grace periods run out. Watch three switches the government already holds and can flip with no consultation.High confidence
Hardest industry wall: Health and social care — My Health Records Act 2012, section 77

CanadaChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: Canada lets data leave the country. There is no approved-country list and no banned-country list. You stay responsible for the data wherever it goes, and you must tell people it may be handled abroad. The catch is that Canada is really ten jurisdictions at once, and several of them add hard storage rules on top of the national one.
The catch: The relaxed national answer stops being true the moment you touch four things: personal information about people in Quebec, a Nova Scotia public body or its suppliers, federal government data rated Protected B or higher, or a federally regulated bank. Add to that a brand-new cyber security law that says records about critical systems in banking, telecoms, energy and transport must be kept in Canada. In those places Canada is genuinely restrictive.
Does this apply to me?: Yes. Canada's national privacy law reaches a foreign company with no office here if it handles personal information about people in Canada as part of doing business. There is no revenue or headcount threshold that lets you out. You do not normally need a local representative, but payment companies are an exception: a payment firm based abroad that aims its service at people in Canada must register with the central bank and name an agent inside Canada to receive official notices.High confidence
Can the data leave the country?: In general, yes, and with no government permission. Canada's national law does not restrict where personal data is stored or processed. But the headline is wrong for at least six groups. Quebec makes you do a written risk assessment first — and that applies even to sending data to Ontario. Nova Scotia public bodies and their suppliers must keep the data in Canada. Federal government data rated Protected B or higher must sit in Canada. Banks must keep a full copy of their records on servers in Canada. And under the new cyber security law, records about critical systems must be kept in Canada.High confidence
What do I have to do to send it abroad?: At the national level there is no list at all — no approved countries, no banned countries, no government form to file. What you must do instead is stay accountable: put a contract or similar protection in place with whoever handles the data for you, and tell people plainly that their information may be processed in another country and could be seen by foreign courts, police or security agencies. Quebec is different and stricter: there you must complete a written privacy risk assessment before the data moves, and sign a written agreement.High confidence
Who enforces this — and are they actually working?: Canada has many regulators and they are all real, staffed and issuing decisions. The national one, the Privacy Commissioner of Canada, published findings against OpenAI, X, Bell and WestJet in the first half of 2026 alone. But it cannot fine anyone — it makes findings and recommendations, and a case has to go to the Federal Court for money. Quebec's regulator can fine, and has blocked a national grocery chain from switching on a face-recognition system. Banking, payments and cyber security each have their own separate supervisor.High confidence
How long must I keep it, and when must I delete it?: The floor and the ceiling pull in opposite directions. Tax law says keep your business records for six years after the tax year they relate to, and keep them at a place of business in Canada unless the tax authority agrees to somewhere else. Privacy law says the opposite: delete personal information once the reason you collected it has gone. Where the two clash, the duty to keep wins — but only for the specific records the law names, and only for as long as it names.High confidence
What happens when something goes wrong?: Count at least four clocks and they do not agree. The national privacy law gives no fixed number of hours — you report 'as soon as feasible', which in practice means days, not weeks. Payment firms get 48 hours to tell the central bank about a serious incident. Critical infrastructure operators will get no more than 72 hours to tell the national cyber agency, then must tell their own regulator immediately after. Health and provincial rules add more. The overlap is where people get caught: one incident, several reports, several deadlines.High confidence
What's the trap?: Five things that are not in any summary. Quebec's cross-border rule catches you sending data to Ontario, not just abroad. Quebec also makes you tell its regulator 60 days before you switch on any face or fingerprint system, and it has already blocked a big grocery chain from doing so. British Columbia repealed its keep-it-in-Canada rule in 2021, so trackers that still show it are wrong. Nova Scotia's Canada-only rule reaches private suppliers, with fines up to half a million dollars. And your tax records have to sit at a place of business in Canada.High confidence
What's about to change?: One big bill and one big law already passed. The bill is Canada's third attempt to replace its 25-year-old privacy law: it would force a written risk assessment before any personal data goes outside Canada, give people a right to have data deleted, treat everyone under 18 as sensitive, and set up a new commissioner. It was only introduced in June 2026 and is not law — do not plan around it as if it were. The law already passed is the cyber security act, which switches on in stages over the coming year.High confidence
Hardest industry wall: Government — Personal Information International Disclosure Protection Act
Government — Direction for Electronic Data Residency (ITPIN 2017-02), with the Policy on Service and Digital
Banking — Guideline B-10 Third-Party Risk Management, read with Bank Act section 245 and the equivalent provisions of the Insurance Companies Act and Trust and Loan Companies Act
All industries — Critical Cyber Systems Protection Act, enacted by the Cyber Security Act (Bill C-8)

The eight framework questions answered for each selected country
Question	AustraliaChecked 18 August 2026	CanadaChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Depends on your industry Work: High Enforcement: Active
In one paragraph	Australia has no general rule that data must stay in the country. You may send personal information anywhere, and no destination is banned. The catch is that you stay legally responsible for whatever your overseas supplier does with it. Small businesses under A$3 million turnover are exempt from the main privacy law. Specific industries are far stricter, and one of them carries a prison sentence.	Canada lets data leave the country. There is no approved-country list and no banned-country list. You stay responsible for the data wherever it goes, and you must tell people it may be handled abroad. The catch is that Canada is really ten jurisdictions at once, and several of them add hard storage rules on top of the national one.
The catch	The relaxed headline stops the moment you touch six areas. National electronic health records may not leave Australia at all, and taking them offshore is a crime punishable by five years in prison. Banks and insurers must tell the banking regulator before any offshore arrangement. Open banking data, critical infrastructure data, Australian Government hosting and Queensland state government data each have their own rules. Check your sector before you believe the headline.	The relaxed national answer stops being true the moment you touch four things: personal information about people in Quebec, a Nova Scotia public body or its suppliers, federal government data rated Protected B or higher, or a federally regulated bank. Add to that a brand-new cyber security law that says records about critical systems in banking, telecoms, energy and transport must be kept in Canada. In those places Canada is genuinely restrictive.
Does this apply to me?	Yes, it reaches you even with no office in Australia. The national privacy law applies to any organisation that carries on business in Australia, whether or not the data is collected or stored here. But Australia has something most countries do not: a real size threshold you can fall below. A business with annual turnover of A$3 million (about US$2 million) or less is generally exempt. That exemption has big holes: it does not apply if you provide a health service, if you buy or sell personal information, or if you supply services under a federal government contract. No local representative and no registration are required.High confidence	Yes. Canada's national privacy law reaches a foreign company with no office here if it handles personal information about people in Canada as part of doing business. There is no revenue or headcount threshold that lets you out. You do not normally need a local representative, but payment companies are an exception: a payment firm based abroad that aims its service at people in Canada must register with the central bank and name an agent inside Canada to receive official notices.High confidence
Can the data leave the country?	In general, yes. Australia has no national law saying personal data must be kept in the country, and no country is blacklisted. You can pick any cloud region you like. What you cannot do is hand off the risk: if your overseas supplier does something with the data that would break Australian rules, the law treats that as your own breach. The hard walls are industry by industry, and the health one is absolute.High confidence	In general, yes, and with no government permission. Canada's national law does not restrict where personal data is stored or processed. But the headline is wrong for at least six groups. Quebec makes you do a written risk assessment first — and that applies even to sending data to Ontario. Nova Scotia public bodies and their suppliers must keep the data in Canada. Federal government data rated Protected B or higher must sit in Canada. Banks must keep a full copy of their records on servers in Canada. And under the new cyber security law, records about critical systems must be kept in Canada.High confidence
What do I have to do to send it abroad?	Before data leaves, you must take reasonable steps to make sure the overseas recipient will handle it the Australian way. In practice that means a contract with the right promises in it. There is no government form to file, no approval to wait for, and no list of approved countries to check. A power to approve countries was switched on in December 2024, but as of today the government has not named a single one. The alternative routes are narrow: you can rely on the recipient already being covered by a substantially similar law, or on the person's informed consent after you warn them you will no longer be responsible.High confidence	At the national level there is no list at all — no approved countries, no banned countries, no government form to file. What you must do instead is stay accountable: put a contract or similar protection in place with whoever handles the data for you, and tell people plainly that their information may be processed in another country and could be seen by foreign courts, police or security agencies. Quebec is different and stricter: there you must complete a written privacy risk assessment before the data moves, and sign a written agreement.High confidence
Who enforces this — and are they actually working?	The Office of the Australian Information Commissioner. It is staffed, it has a sitting Privacy Commissioner, and it is issuing decisions. In October 2025 the Federal Court ordered a pathology company to pay A$5.8 million (about US$3.8 million), the first court penalty in the law's history. The regulator sued Optus in August 2025, settled with Meta for A$50 million in December 2024, and in June 2026 alone published formal findings against Optus, American Express and two health providers. Banking, cyber security, online safety and open banking each have their own separate regulator, and all of them are working.High confidence	Canada has many regulators and they are all real, staffed and issuing decisions. The national one, the Privacy Commissioner of Canada, published findings against OpenAI, X, Bell and WestJet in the first half of 2026 alone. But it cannot fine anyone — it makes findings and recommendations, and a case has to go to the Federal Court for money. Quebec's regulator can fine, and has blocked a national grocery chain from switching on a face-recognition system. Banking, payments and cyber security each have their own separate supervisor.High confidence
How long must I keep it, and when must I delete it?	There is a floor and a ceiling and they pull in opposite directions. The clearest floor is telecoms: phone and internet providers must keep call and connection records for two years, and must encrypt them. The general ceiling has no number attached — you must destroy or de-identify personal information once you genuinely no longer need it. Two ceilings are sharp. A social media platform must destroy age-check information as soon as it has finished using it. A digital identity provider must destroy a face or fingerprint scan immediately after the identity check is complete.High confidence	The floor and the ceiling pull in opposite directions. Tax law says keep your business records for six years after the tax year they relate to, and keep them at a place of business in Canada unless the tax authority agrees to somewhere else. Privacy law says the opposite: delete personal information once the reason you collected it has gone. Where the two clash, the duty to keep wins — but only for the specific records the law names, and only for as long as it names.High confidence
What happens when something goes wrong?	Count four clocks, because they run at different speeds. If you pay a ransom and your Australian turnover is above A$3 million (about US$2 million), you have 72 hours to report the payment to the government. If you run critical infrastructure, you have 12 hours for an attack that seriously hits availability, and 72 hours for a lesser one. If you are a bank, insurer or superannuation fund, you have 72 hours for a security incident and only 24 hours if a critical service goes down beyond tolerance. For an ordinary personal data breach you get up to 30 days to assess whether it is serious, then you must tell the regulator and the affected people as soon as you practically can. There is no fixed hour count for that last one, which is the part people get wrong.High confidence	Count at least four clocks and they do not agree. The national privacy law gives no fixed number of hours — you report 'as soon as feasible', which in practice means days, not weeks. Payment firms get 48 hours to tell the central bank about a serious incident. Critical infrastructure operators will get no more than 72 hours to tell the national cyber agency, then must tell their own regulator immediately after. Health and provincial rules add more. The overlap is where people get caught: one incident, several reports, several deadlines.High confidence
What's the trap?	Five things that will cost you a weekend. First, moving national electronic health record data offshore is a crime, not a fine: up to five years in prison. Second, you never stop owning your supplier's mistakes — a major bank had to get a special ruling from the Privacy Commissioner just to keep processing international money transfers. Third, since December 2025 social media platforms must keep under-16s off the service and then destroy the age-check data they collected. Fourth, Queensland's rule for state government data is stricter than the national one and is hidden in section 33 of the Act, not in the numbered principles — the principle numbered 8 says there is no equivalent. Fifth, the value of a penalty unit rose to A$364 (about US$240) on 1 July 2026, so every fine figure you looked up before then is now understated.High confidence	Five things that are not in any summary. Quebec's cross-border rule catches you sending data to Ontario, not just abroad. Quebec also makes you tell its regulator 60 days before you switch on any face or fingerprint system, and it has already blocked a big grocery chain from doing so. British Columbia repealed its keep-it-in-Canada rule in 2021, so trackers that still show it are wrong. Nova Scotia's Canada-only rule reaches private suppliers, with fines up to half a million dollars. And your tax records have to sit at a place of business in Canada.High confidence
What's about to change?	One date dominates: 10 December 2026. On that day privacy policies must start explaining computer-made decisions that significantly affect people, and the new Children's Online Privacy Code must be finalised and registered. The draft of that code was out for public comment from 31 March to 5 June 2026. Further out, the tougher critical infrastructure duties made in June 2026 start biting from mid-2027 and mid-2028 as their grace periods run out. Watch three switches the government already holds and can flip with no consultation.High confidence	One big bill and one big law already passed. The bill is Canada's third attempt to replace its 25-year-old privacy law: it would force a written risk assessment before any personal data goes outside Canada, give people a right to have data deleted, treat everyone under 18 as sensitive, and set up a new commissioner. It was only introduced in June 2026 and is not law — do not plan around it as if it were. The law already passed is the cyber security act, which switches on in stages over the coming year.High confidence
Hardest industry wall	Health and social care — My Health Records Act 2012, section 77	Government — Personal Information International Disclosure Protection Act Government — Direction for Electronic Data Residency (ITPIN 2017-02), with the Policy on Service and Digital Banking — Guideline B-10 Third-Party Risk Management, read with Bank Act section 245 and the equivalent provisions of the Insurance Companies Act and Trust and Loan Companies Act All industries — Critical Cyber Systems Protection Act, enacted by the Cyber Security Act (Bill C-8)