Compare countries
Two or three countries, side by side, one row per question. Pick up to 3.
FranceChecked 18 August 2026
Depends on your industryWork: HighEnforcement: Aggressive
- In one paragraph
- France follows the European rule: data may leave, but only once the right paperwork is in place. France then adds hard walls of its own. Health records must be stored inside Europe. Online gambling records must sit on a machine in mainland France. From 1 September 2026 the invoicing platform every French business must use has to run entirely from inside Europe.
- The catch
- "France has no local storage rule" is true for an ordinary business and false the moment you touch health data, online gambling, electronic invoicing or a government contract involving sensitive state data. In those four areas France is among the strictest countries in Europe. Since March 2026 the health rule sits in a decree, not just a certification standard, so it now binds the customer as well as the supplier.
- Does this apply to me?
- Yes. France reaches a company with no office in the country. European law already applies to anyone offering goods or services to people in Europe. On top of that, France's own privacy law says its national rules apply as soon as the person concerned lives in France, even when the company is based somewhere else. There is no size or revenue threshold that lets you escape.High confidence
- Can the data leave the country?
- For an ordinary business, yes, with paperwork: the European transfer rules apply and nothing extra is added. But four French sectors override that. Health records must be stored inside Europe and nowhere else. Online gambling records must be archived in real time on hardware in mainland France. Electronic invoicing platforms must run their whole system from inside Europe. And sensitive state data must sit on a cloud that the French cyber agency has certified as beyond the reach of foreign authorities.High confidence
- What do I have to do to send it abroad?
- The model is an approved-list one, run from Brussels rather than Paris. Data may go to a country the European Commission has formally approved, or anywhere else if you sign the official standard contract and write down why you think the data will still be safe. The list of approved countries is full, not empty: it includes the United Kingdom, Japan, South Korea, Canada, Switzerland, Brazil and about a dozen others, plus American companies that have signed up to the transatlantic framework. France adds no separate national approval step.High confidence
- Who enforces this — and are they actually working?
- The privacy regulator is the CNIL, and it is one of the busiest in Europe. In 2025 alone it issued 83 penalties totalling about 487 million euros (roughly 530 million dollars), plus 143 formal warnings. It is still fining in 2026: 5 million euros against the national employment agency in January and 5 million against a health data company in May. Separate regulators run the sector walls, and all of them are staffed and 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. You must keep accounting books and supporting documents for ten years, tax records for six, employment contracts and pay records for five, and telephone and internet subscriber identity data for five. In the other direction, European law says you must delete personal data once you no longer need it. France resolves the clash the same way most of Europe does: the legal minimum wins, but only for the specific documents the law names, and only for as long as it names.High confidence
- What happens when something goes wrong?
- Count the clocks, because France has at least four and they run at different speeds. Every organisation has 72 hours to tell the CNIL about a personal data breach. Telephone and internet providers have only 24 hours. Hospitals and clinics must report a serious computer security incident to their regional health agency immediately. Banks, insurers and investment firms have their own European deadlines: an initial report within 4 hours of classifying a major incident and no later than 24 hours after they notice it.High confidence
- What's the trap?
- Five things that are not in the summary. (1) Breaking the privacy law in France is a crime, not just a fine: sending data out of Europe unlawfully carries up to five years in prison and a 300,000 euro fine (about 330,000 dollars), and it attaches to people, not only companies. (2) A child is anyone under 15 for consent, not 13 or 16. (3) A 2023 law setting a social media age of 15 is printed in the statute book but has never come into force and cannot be enforced. (4) Handing documents to a foreign court or regulator can itself be a criminal offence in France. (5) Cookies are policed separately from the rest of privacy law, so a foreign company cannot hide behind its lead European regulator.High confidence
- What's about to change?
- Four dates in the next twelve months. 1 September 2026: every French business must be able to send and receive invoices through an approved platform, and those platforms must run entirely from inside Europe. Around 27 September 2026: the second phase of the health data hosting decree starts. 21 October 2026: the order forcing telephone and internet companies to keep everyone's connection records for a year expires unless the Prime Minister renews it. 12 January 2027: cloud providers across Europe must drop switching and data export fees to zero.Medium confidence
- Hardest industry wall
- Health and social care — Decret n° 2026-209 du 24 mars 2026 portant modification de certaines dispositions du code de la sante publique relatives a l'hebergement de donnees de sante a caractere personnel
- Government — Decret n° 2026-272 du 14 avril 2026 relatif a la protection des donnees d'une sensibilite particuliere des administrations, operateurs et groupements d'interet public de l'Etat traitees par un service d'informatique en nuage fourni par un prestataire prive
- All industries — Immatriculation des plateformes agreees (ex plateformes de dematerialisation partenaires) - facturation electronique
- Online gaming — Article 31 de la loi n° 2010-476 du 12 mai 2010 relative a l'ouverture a la concurrence et a la regulation du secteur des jeux d'argent et de hasard en ligne
GreeceChecked 18 August 2026
Depends on your industryWork: HighEnforcement: Active
- In one paragraph
- For most businesses Greece is a normal European country: personal data can leave, as long as you use one of the standard European transfer tools. But Greece has two hard walls that Europe does not. Phone and internet connection records must physically sit on machines inside Greece. Online gambling operators must keep their records on a server inside Greece too. The privacy regulator is fully staffed and fining companies today.
- The catch
- The relaxed European headline stops being true the moment you touch three things. Telecoms connection records must be stored on physical media inside Greek territory for twelve months. Online gambling records must sit on a server or safe inside Greece for ten years. And Greek public bodies must run their central systems on the Greek state's own clouds, not on a commercial cloud of their choosing. Outside those three, plus the health and public sectors, Greece imposes no storage-location rule of its own.
- Does this apply to me?
- Yes, it reaches a foreign company with no office in Greece. The European privacy rules apply to anyone anywhere who offers goods or services to people in Greece, or who watches what they do online. The Greek national law adds that it also covers anyone processing data on Greek soil. There is no size or revenue threshold that lets you off. If you have no establishment anywhere in Europe, you must appoint a written representative inside the European Union.High confidence
- Can the data leave the country?
- In general, yes. Greece adds no storage-location rule of its own to the European baseline, so ordinary business data can be sent abroad once you have the right European transfer paperwork. Three industries break that rule completely. Telecoms companies must keep their connection records on machines physically inside Greece. Online gambling operators must keep their records on a server inside Greece. And Greek government bodies must run their main systems on state-operated clouds. Health, banking and insurance have extra hoops but no location rule.High confidence
- What do I have to do to send it abroad?
- You need one of the standard European transfer tools before data leaves Europe. The simplest is sending it to a country the European Commission has already approved. If the destination is not approved, you sign the European Commission's standard contract with the recipient, or use approved group-wide internal rules, and you write down why you think the data will still be safe there. Greece adds no extra permission, filing or fee of its own.High confidence
- Who enforces this — and are they actually working?
- Six bodies, and all six are genuinely working. The Hellenic Data Protection Authority is the main privacy regulator and is issuing numbered decisions and fines every month — its most recent published decisions run to July 2026 and include fines on a bank and an electricity supplier. A separate constitutional authority polices the secrecy of communications. There is also a national cybersecurity authority, a telecoms regulator, the central bank for finance and insurance, and a gambling regulator. This is not a paper regime.High confidence
- How long must I keep it, and when must I delete it?
- Both directions apply, and they collide. Business books must be kept five years. Medical files must be kept ten years in a private practice and twenty years everywhere else. Online gambling records must be kept ten years. Telecoms connection records must be kept exactly twelve months and then automatically deleted. In the other direction, the European rule says you must not keep personal data longer than you need it. When a specific keeping rule and the general deleting rule clash, the specific keeping rule wins.High confidence
- What happens when something goes wrong?
- Count three clocks, not one. If personal data is lost or exposed, you have 72 hours to tell the privacy regulator. If you run important infrastructure, you have only 24 hours to send a first warning to the national cybersecurity authority, then 72 hours for a fuller report and one month for the final one. If you are a phone or internet provider, you have 24 hours to report a personal data breach and a separate duty to tell the communications secrecy authority. Missing the 24-hour clocks is the most common failure.High confidence
- What's the trap?
- Five things that will cost you a weekend. First, a child in Greece can consent to an online service at fifteen, not sixteen — so an age gate built to the European default is set wrong. Second, misusing personal data is a crime here, with prison time, not just a fine. Third, several articles of the Greek privacy law are printed in the statute but the regulator has formally said they must not be applied, because they clash with European law. Fourth, telecoms connection records must physically stay in Greece. Fifth, government bodies cannot simply pick a commercial cloud.High confidence
- What's about to change?
- Three dated changes. Electronic invoicing between businesses became compulsory for large Greek companies on 2 March 2026 and becomes compulsory for everyone else on 1 October 2026. Greece's new artificial intelligence law took effect on 22 July 2026 and forces public bodies to register every artificial intelligence system before switching it on. And from 12 January 2027 European law bans cloud providers from charging you to move your data out.High confidence
- Hardest industry wall
- Telecoms — Νόμος 3917/2011 — Διατήρηση δεδομένων που παράγονται ή υποβάλλονται σε επεξεργασία σε συνάρτηση με την παροχή υπηρεσιών ηλεκτρονικών επικοινωνιών
- Online gaming — Νόμος 4002/2011 — Ρύθμιση της αγοράς παιγνίων, άρθρο 47, και Κανονισμοί Παιγνίων (ΥΑ 79305/2020 και 79835/2020)
- Government — Νόμος 4727/2020 — Ψηφιακή Διακυβέρνηση, άρθρο 87 (Κυβερνητικά νέφη)