Compare countries
Two or three countries, side by side, one row per question. Pick up to 3.
GeorgiaChecked 18 August 2026
Yes, with paperworkWork: HighEnforcement: Waking up
- In one paragraph
- Georgia copied the European model in 2023: data can leave the country, but only to a destination the supervisor has approved, or with a permit, or under a narrow exception. There is no general rule forcing data to stay. The big change is who is in charge — on 2 March 2026 the independent privacy watchdog was replaced by the State Audit Office, and we could not verify that it has issued a single decision since.
- The catch
- Two things break the calm headline. Telephone and internet connection records are copied into a state-held database inside Georgia, so telecoms cannot treat that data as ordinary business data. And the same State Audit Office that now polices privacy also runs the public register of foreign-funded organisations.
- Does this apply to me?
- Yes. The law catches a company with no office in Georgia if it uses technical means located in Georgia to handle people's data. There is no revenue or headcount threshold to duck under. Worse, a foreign company in that position must appoint a representative in Georgia and register that person with the supervisor BEFORE it starts processing — the only escape is being based in the European Union or in a country the European Union has already approved.High confidence
- Can the data leave the country?
- Yes, with paperwork. Data may go abroad if the destination country has been judged to give good enough protection, or if the supervisor grants a permit for the contract you have signed, or under a short list of narrow exceptions such as the person's written consent after being told the risks. Nothing in the general law forces data to stay in Georgia. The one place data really does stay is telecoms: a copy of who called whom, and when, sits in a state-run database inside the country.High confidence
- What do I have to do to send it abroad?
- The model is an approved-destinations list, with a permit as the back-up. The supervisor decides which countries offer good enough protection and publishes that decision as a formal act; if your destination is not on it, you need a permit for your contract, or you fall back on a narrow exception such as written consent. We could not find the current published list, so we cannot tell you today which countries are on it — treat that as the single biggest open question in this record.Medium confidence
- Who enforces this — and are they actually working?
- This is where Georgia surprises people. Until 1 March 2026 the job belonged to the Personal Data Protection Service, an independent watchdog. From 2 March 2026 the law hands the same job to the State Audit Office — the body that audits government spending — and its head, the Auditor General, now signs the privacy rules. We can prove the handover happened, because the Auditor General reissued two of the privacy rulebooks at the end of March 2026. We could not find a single enforcement decision published since the handover.Medium confidence
- How long must I keep it, and when must I delete it?
- The ceiling is clear: keep personal data only as long as you need it for the purpose you collected it for, then erase, destroy or strip out the identifying parts, unless another law tells you to keep it. The floors are scattered across tax, accounting and sector laws that we could not open on an official site today. In telecoms the direction is reversed — the content of a call or message must be destroyed at once, while the record of who contacted whom can be copied into a state database and kept for a period set by a separate law.Medium confidence
- What happens when something goes wrong?
- Two clocks. If personal data is lost, leaked or wrongly handled, you have 72 hours from spotting it to tell the supervisor, and you must keep your own record of the incident and what you did about it. If you run a system the government has listed as critical to the country, you must tell the national computer emergency response team immediately — no fixed number of hours, which in practice means the same day. If both apply to you, both run at once.High confidence
- What's the trap?
- Five. First, the regulator changed identity on 2 March 2026, so a privacy notice or contract naming the Personal Data Protection Service now points at a body the law no longer mentions. Second, a foreign company must register a representative in Georgia before it starts, not after. Third, a child is anyone under 16, so a European sign-up flow tuned to 13 will be wrong here. Fourth, direct marketing always needs consent, even if you bought the list lawfully. Fifth, the same State Audit Office that now polices privacy also runs the public register of foreign-funded organisations, which must publish detailed information about themselves.Medium confidence
- What's about to change?
- Nothing new is scheduled to start in the privacy law itself — we checked the current text on 18 August 2026 and found no provisions waiting on a future date. The live story is the handover: the Auditor General is reissuing the four rulebooks inherited from the old watchdog, and two of the four were reissued in March 2026. The rest of the risk sits in switches the government can already flip without a new law.Medium confidence
- Hardest industry wall
- Telecoms — საქართველოს კანონი ელექტრონული კომუნიკაციების შესახებ
ChinaChecked 18 August 2026
Yes, with paperworkWork: Very highEnforcement: Active
- In one paragraph
- Data can leave China, but only through one of three official gates: a government security review, a government-written contract you file with the regulator, or a certificate from an approved body. Which gate you need depends on how many people's data you move, not on where you send it. Small exporters are exempt. Several industries are walled off entirely.
- The catch
- The 'paperwork, then it can go' answer is only true for ordinary companies. Payment firms, credit bureaus, hospitals, genetic labs, online map services, telecom and industrial operators, and anything the government labels critical national infrastructure must keep the data in China. In those areas a copy staying behind is not optional.
- Does this apply to me?
- Yes. China's privacy law reaches a company with no office and no staff in China if it offers goods or services to people in China, or analyses their behaviour. There is no revenue or headcount threshold that lets you out. If you are caught this way, you must set up a dedicated office in China or name a representative there, and give the regulator their details.High confidence
- Can the data leave the country?
- In general yes, once you clear the right gate — but the gate is set by volume, not by destination. China has no list of banned or approved countries. Below 100,000 people a year you can usually send data abroad with no filing at all. Above that you need a contract filed with the regulator or a certificate; above a million people, or if you hold data the state calls 'important', you need a full government security review. Then come the industry walls, which override all of this.High confidence
- What do I have to do to send it abroad?
- Three routes, and you do not get to pick freely — your volume picks for you. Route one is a government security review, run by the national internet regulator through your provincial office; an approval lasts three years and only covers the exact purpose, scope and method you declared. Route two is China's own standard contract, which you sign with the overseas recipient and file with the provincial regulator along with a risk assessment. Route three is a certificate from an accredited body, which since 1 March 2026 has a national standard behind it. You also need each person's separate, specific consent before their data goes abroad.High confidence
- Who enforces this — and are they actually working?
- The Cyberspace Administration of China leads, and it is fully staffed and busy. It runs a nationwide enforcement campaign every year, tests apps itself and publishes the names of the ones that fail, and puts out batches of worked enforcement cases. Police, the industry ministry and the market regulator enforce alongside it, and finance, health, mapping and securities regulators run their own rules. Fines are usually modest and paired with an order to fix things; the eye-watering penalties in the statute are rarely used.High confidence
- How long must I keep it, and when must I delete it?
- Both directions apply, and they pull against each other. The floor: network logs must be kept for at least six months, and accounting records have their own long minimum periods set by a national schedule. The ceiling: personal data may only be kept for the shortest time needed for the purpose you collected it for, and must be deleted once that purpose is met, the service ends, or consent is withdrawn. Where a law sets a minimum, that minimum wins over the delete duty — you keep the record and stop using it for anything else.High confidence
- What happens when something goes wrong?
- Three clocks, and they overlap. If you run critical national infrastructure you have ONE HOUR to report a serious incident to your supervising department and the police. Everyone else has four hours to tell the provincial internet office. On top of that, a network data incident that could harm national security or the public interest must be reported within 24 hours. You must also tell affected people immediately, by phone, text, message, email or public notice.High confidence
- What's the trap?
- Five things that ruin weekends. (1) Sending data abroad needs each person's separate, specific consent — a line buried in a global privacy notice will not do. (2) A child is anyone under 14, and their data is treated as sensitive, so you need a parent's consent and a separate set of processing rules. (3) You may not hand data stored in China to a foreign court, police force or regulator without Chinese government approval — this catches routine legal discovery and overseas audit requests. (4) You have to work out for yourself whether you hold 'important data' and report it, because the official catalogues are incomplete. (5) The widely repeated claim that all personal financial data must be stored in China does not appear where people think it does.High confidence
- What's about to change?
- The next twelve months are about size-based rules. A draft published on 7 August 2026 would create a heavy new tier for any company holding data on ten million people or more: store it in China, appoint a chief privacy officer, set up an outside supervision committee, publish an annual report and honour data portability requests within 30 working days. Comments closed on 7 September 2026 and it is not law yet. A companion draft going the other way would simplify life for small processors. Watch the dormant switches — several can flip with no consultation at all.High confidence
- Hardest industry wall
- All industries — 中华人民共和国网络安全法(2025年修正)
- Payments — 非银行支付机构监督管理条例
- Finance — 征信业务管理办法
- Banking — 中国人民银行业务领域数据安全管理办法
- Securities — 关于加强境内企业境外发行证券和上市相关保密和档案管理工作的规定
- Health and social care — 国家健康医疗大数据标准、安全和服务管理办法(试行)
- Mapping and location — 地图管理条例
- Telecoms — 工业和信息化领域数据安全管理办法(试行)