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

United KingdomChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Active

In one paragraph: Data can leave the United Kingdom, but you need the right paperwork first. Sending it to Europe or to about fifteen other approved places needs nothing extra. Anywhere else needs a government-published contract and a risk check. No general law forces data to stay in Britain. The privacy regulator is busy and its fines are getting bigger.
The catch: The easy headline stops being true in three places. Telecoms operators must keep backup copies of key network information inside the United Kingdom. National Health Service patient records may only be sent to countries the United Kingdom has formally approved, which rules out the standard contract route. And government material classified SECRET or above cannot sit in public cloud at all. Everyone else can store data abroad with the right contract in place.
Does this apply to me?: Yes. British privacy law reaches a company anywhere in the world if it deliberately offers goods or services to people in the United Kingdom, or watches what they do online. There is no size or revenue floor to hide under. If you are caught and have no British office, you generally have to name a representative in the United Kingdom, unless you are a public body or your processing is rare and low risk.High confidence
Can the data leave the country?: Yes, with paperwork. The United Kingdom has no general law forcing data to stay in the country. Send it to the European Economic Area or another approved country and you need nothing extra; send it anywhere else and you need an approved contract plus a written risk assessment. Three industries are stricter: telecoms, the health service and classified government work. Banking, payments, insurance, securities, education, online gambling and mapping have no location rule that we could find.High confidence
What do I have to do to send it abroad?: The model is an approved-list one. If the destination is on the government's approved list you may send data with no extra paperwork. If it is not, you must sign the government's own contract template and run a risk assessment first. The list is well populated: the whole European Economic Area plus Andorra, Argentina, the Faroe Islands, Gibraltar, Guernsey, the Isle of Man, Israel, Jersey, New Zealand, South Korea, Switzerland and Uruguay, with partial cover for Canada, Japan and the United States.High confidence
Who enforces this — and are they actually working?: The Information Commissioner's Office, and it is very much working. It fined Capita fourteen million pounds (about $18 million) in October 2025, Reddit £14.47 million (about $18.5 million) in February 2026, and the owner of Imgur in the same month, and it issues smaller marketing fines almost monthly. Watch a quirk: a replacement body called the Information Commission legally exists but had no staff and did no work in its first financial year, so the old office is still the one that acts.High confidence
How long must I keep it, and when must I delete it?: There is no single deletion deadline. The rule is that you keep personal data only as long as you actually need it, and you must be able to explain the period you chose. Pulling the other way are minimum keeping periods: company and tax records for six years, telecoms connection records for up to twelve months if the government serves a notice, and telecoms security data for thirteen months. Where a minimum and a maximum clash, the legal duty to keep wins and you keep the data.High confidence
What happens when something goes wrong?: Count at least three clocks. Any organisation has 72 hours to tell the privacy regulator about a personal data breach, and must tell the affected people if the risk to them is high. Telecoms and internet providers also have 72 hours under the electronic communications rules — that used to be 24 hours and quietly changed on 20 August 2025. Operators of essential services such as water, energy and transport have their own 72-hour clock to their own regulator.High confidence
What's the trap?: Five. (1) A child can consent at 13 here, not 16 — but the children's design code covers everyone under 18, and the regulator fined Reddit £14.47 million (about $18.5 million) for weak age checks. (2) Telecoms firms must keep some backup data physically in Britain. (3) Health service data can only go to approved countries, so the standard contract does not help you. (4) Misusing personal data can be a crime, not just a fine. (5) The government can secretly order a company to weaken its security, and Apple is fighting one of those orders right now.Medium confidence
What's about to change?: Two things to watch in the next twelve months. A cyber security bill is going through Parliament and will widen incident reporting to data centres and managed service suppliers — it is not law yet, so do not plan as if it were. And the privacy regulator is due to be replaced by a new body called the Information Commission, but only once ministers lay the paperwork, which had not happened by mid-2026. The regulator is also writing a statutory code on artificial intelligence.High confidence
Hardest industry wall: Telecoms — The Electronic Communications (Security Measures) Regulations 2022, with the Telecommunications Security Code of Practice 2026 (version 1.1)

The eight framework questions answered for each selected country
Question	AustraliaChecked 18 August 2026	United KingdomChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Yes, with paperwork 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.	Data can leave the United Kingdom, but you need the right paperwork first. Sending it to Europe or to about fifteen other approved places needs nothing extra. Anywhere else needs a government-published contract and a risk check. No general law forces data to stay in Britain. The privacy regulator is busy and its fines are getting bigger.
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 easy headline stops being true in three places. Telecoms operators must keep backup copies of key network information inside the United Kingdom. National Health Service patient records may only be sent to countries the United Kingdom has formally approved, which rules out the standard contract route. And government material classified SECRET or above cannot sit in public cloud at all. Everyone else can store data abroad with the right contract in place.
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. British privacy law reaches a company anywhere in the world if it deliberately offers goods or services to people in the United Kingdom, or watches what they do online. There is no size or revenue floor to hide under. If you are caught and have no British office, you generally have to name a representative in the United Kingdom, unless you are a public body or your processing is rare and low risk.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	Yes, with paperwork. The United Kingdom has no general law forcing data to stay in the country. Send it to the European Economic Area or another approved country and you need nothing extra; send it anywhere else and you need an approved contract plus a written risk assessment. Three industries are stricter: telecoms, the health service and classified government work. Banking, payments, insurance, securities, education, online gambling and mapping have no location rule that we could find.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	The model is an approved-list one. If the destination is on the government's approved list you may send data with no extra paperwork. If it is not, you must sign the government's own contract template and run a risk assessment first. The list is well populated: the whole European Economic Area plus Andorra, Argentina, the Faroe Islands, Gibraltar, Guernsey, the Isle of Man, Israel, Jersey, New Zealand, South Korea, Switzerland and Uruguay, with partial cover for Canada, Japan and the United States.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	The Information Commissioner's Office, and it is very much working. It fined Capita fourteen million pounds (about $18 million) in October 2025, Reddit £14.47 million (about $18.5 million) in February 2026, and the owner of Imgur in the same month, and it issues smaller marketing fines almost monthly. Watch a quirk: a replacement body called the Information Commission legally exists but had no staff and did no work in its first financial year, so the old office is still the one that acts.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	There is no single deletion deadline. The rule is that you keep personal data only as long as you actually need it, and you must be able to explain the period you chose. Pulling the other way are minimum keeping periods: company and tax records for six years, telecoms connection records for up to twelve months if the government serves a notice, and telecoms security data for thirteen months. Where a minimum and a maximum clash, the legal duty to keep wins and you keep the data.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 three clocks. Any organisation has 72 hours to tell the privacy regulator about a personal data breach, and must tell the affected people if the risk to them is high. Telecoms and internet providers also have 72 hours under the electronic communications rules — that used to be 24 hours and quietly changed on 20 August 2025. Operators of essential services such as water, energy and transport have their own 72-hour clock to their own regulator.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. (1) A child can consent at 13 here, not 16 — but the children's design code covers everyone under 18, and the regulator fined Reddit £14.47 million (about $18.5 million) for weak age checks. (2) Telecoms firms must keep some backup data physically in Britain. (3) Health service data can only go to approved countries, so the standard contract does not help you. (4) Misusing personal data can be a crime, not just a fine. (5) The government can secretly order a company to weaken its security, and Apple is fighting one of those orders right now.Medium 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	Two things to watch in the next twelve months. A cyber security bill is going through Parliament and will widen incident reporting to data centres and managed service suppliers — it is not law yet, so do not plan as if it were. And the privacy regulator is due to be replaced by a new body called the Information Commission, but only once ministers lay the paperwork, which had not happened by mid-2026. The regulator is also writing a statutory code on artificial intelligence.High confidence
Hardest industry wall	Health and social care — My Health Records Act 2012, section 77	Telecoms — The Electronic Communications (Security Measures) Regulations 2022, with the Telecommunications Security Code of Practice 2026 (version 1.1)