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Countries

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)

United StatesChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
The catch: The open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
Does this apply to me?: Yes. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from Europe.High confidence
Can the data leave the country?: It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.High confidence
What do I have to do to send it abroad?: For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.High confidence
Who enforces this — and are they actually working?: Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.High confidence
How long must I keep it, and when must I delete it?: There is a strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.High confidence
What happens when something goes wrong?: Count the clocks — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.High confidence
What's the trap?: Five that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.High confidence
What's about to change?: Four things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.High confidence
Hardest industry wall: Government — Criminal Justice Information Services (CJIS) Security Policy
Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies
Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services
Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector

The eight framework questions answered for each selected country
Question	United KingdomChecked 18 August 2026	United StatesChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Active	Depends on your industry Work: High Enforcement: 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.	In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
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.	The open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
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	Yes. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from Europe.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	It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.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	For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.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	Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.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	There is a strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.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	Count the clocks — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.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	Five that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.High 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	Four things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.High confidence
Hardest industry wall	Telecoms — The Electronic Communications (Security Measures) Regulations 2022, with the Telecommunications Security Code of Practice 2026 (version 1.1)	Government — Criminal Justice Information Services (CJIS) Security Policy Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector