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

Countries

Hong Kong SARChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Hong Kong's privacy law contains a cross-border transfer ban that has never been switched on. It was written in 1995 and, thirty years later, still has no start date. So under the general law you can send personal data anywhere with no paperwork at all. The privacy regulator is busy and prosecutes people, but it cannot fine you directly.
The catch: The free-for-all stops at three doors. Licensed securities and futures firms need written permission from the markets regulator before their records live only on servers outside Hong Kong. Government departments are told not to put sensitive or personal information on public cloud at all. And data coming the other way, from mainland China into Hong Kong, is tightly controlled by mainland law, not by Hong Kong law - that is the wall most companies actually hit.
Does this apply to me?: Yes, it can reach you with no office in Hong Kong. The privacy law bites on whoever controls the collection, holding, use or processing of personal data in or from Hong Kong, so a foreign company running a Hong Kong-facing service is caught. There is no revenue or headcount threshold to fall below, no register to join, and no requirement to appoint a local representative. The anti-doxxing powers go further still: the regulator can order an overseas platform to take material down.High confidence
Can the data leave the country?: Under the general privacy law, yes - freely, with nothing to sign. The one section that would have restricted transfers abroad was written into the law in 1995 and has never been brought into operation, so today there is no legal control on personal data leaving Hong Kong. Industry rules are where the real limits sit, and there are fewer of them than people expect: the securities regulator is the main one, and government departments have their own restriction.High confidence
What do I have to do to send it abroad?: Nothing. There is no approval to seek, no standard contract to sign and no government list to check before personal data leaves Hong Kong. The model on paper is an allowlist - the regulator would publish a list of approved destinations - but because the section was never switched on, that list has never been issued and is empty. The regulator does publish a voluntary guide and encourages firms to build the safeguards now, but that is advice, not law.High confidence
Who enforces this — and are they actually working?: The Privacy Commissioner for Personal Data, and it is genuinely busy. By the end of December 2025 it had issued 2,104 orders to 57 online platforms to take down 33,743 doxxing messages, opened 519 criminal investigations and arrested 81 people. But there is a catch that changes the risk picture completely: the Commissioner cannot impose a fine for breaking the privacy principles. It serves a notice telling you to fix the problem, and only ignoring that notice is a crime.High confidence
How long must I keep it, and when must I delete it?: There is a hard ceiling and almost no floor in the privacy law itself. You must erase personal data once it is no longer needed for the purpose you collected it for, and failing to do so is a criminal offence carrying a fine of up to HK$10,000 (about $1,300). The privacy law sets no minimum keeping periods; those come from tax, company and anti-money-laundering law instead. Where the two pull against each other, the specific keeping duty in the other law wins, and you delete once it expires.Medium confidence
What happens when something goes wrong?: For a normal data breach there is no deadline, because there is no duty. Telling the Privacy Commissioner about a breach is voluntary in Hong Kong - the regulator asks you to do it as good practice and gives you a form, but no law compels it. That is unusual and it is changing: since 1 January 2026 operators of designated critical infrastructure must report computer-system security incidents, so those firms now have a real clock while everyone else has none.High confidence
What's the trap?: Five things that catch people out. First, marketing mistakes are crimes here, not fines - using someone's data for direct marketing without the right consent can mean five years in prison. Second, the regulator cannot fine you, so people assume the risk is low and miss the criminal exposure entirely. Third, Hong Kong sets no age at which a child can consent, so there is no simple number to code into a sign-up flow. Fourth, licensed securities firms need written permission before their records live only on overseas servers, and two named people who live in Hong Kong must be able to unlock them. Fifth, the dormant transfer section, if ever switched on, would also catch data moving between two foreign countries when a Hong Kong company controls it.Medium confidence
What's about to change?: Nothing is scheduled to land in the next twelve months that we could confirm. The critical infrastructure security law already started on 1 January 2026, and the government's guideline for generative artificial intelligence was revised in December 2025. The thing to watch is not a new bill. It is a switch the government has held for thirty years: the cross-border transfer section can be brought into force by a simple commencement notice, with no consultation and no new vote.Medium confidence
Hardest industry wall: None found.

ArgentinaChecked 18 August 2026

Yes, with paperworkWork: MediumEnforcement: Active

In one paragraph: Argentina lets personal data leave the country, but only on paper terms it sets. You either send it to a country the regulator has approved, or you sign the regulator's own model contract with the receiver. No industry has to keep data inside Argentina. Fines are tiny in dollars, but the regulator can order a database shut down, and some misuse is a crime.
The catch: There is no data-residency wall in Argentina, but four sector rules still catch people out. Banks and payment firms must run their technology and security management from inside Argentina, must tell the banking supervisor before they outsource, and must report a cyber incident within one hour. Government bodies must have a working backup data centre by late 2026. And nobody may publish a map showing Argentine territory without the national mapping agency's prior approval.
Does this apply to me?: The main privacy law is Ley 25.326, passed in 2000. It covers personal data held in any file or database in Argentina, public or private. There is no size threshold, no revenue threshold, and no duty to appoint a local representative. The law does not clearly say it reaches a foreign company with no presence in Argentina, and in practice the regulator has acted against local subsidiaries of global firms rather than against foreign entities directly.High confidence
Can the data leave the country?: Yes, with paperwork. The rule is that personal data may not go to a country that does not protect it well enough. The regulator publishes a list of countries it accepts, and for everywhere else you sign its model contract with the receiver. We looked for industries that must keep data inside Argentina - banking, payments, insurance, securities, health, telecoms, government cloud and mapping - and found none as of 18 August 2026.High confidence
What do I have to do to send it abroad?: The model is an approved-destinations list, and it is populated today with about a dozen places, including the whole European Union. If your destination is not on it, use the regulator's published model contract - two versions, one for handing data to another company that decides how to use it and one for a supplier processing it for you. Using the published wording needs no permission. If you change the wording, you must file the contract with the regulator within 30 days of signing.High confidence
Who enforces this — and are they actually working?: The Agency for Access to Public Information, known by its Spanish initials AAIP, enforces both privacy and freedom of information. It is real and working: it has a named head, it publishes a register of final penalties that was updated on 3 July 2026, it opened a public investigation into debt-collection calls in April 2026, and it chaired an international data-protection committee in July 2026. Its 244 final penalties are mostly small, and more than half are for calling people on the do-not-call list.High confidence
How long must I keep it, and when must I delete it?: Argentina has strong floors and one hard ceiling. Anti-money-laundering rules make banks, insurers, crypto firms, accountants and estate agents keep transaction records and customer files for at least ten years. Clinical records must be kept ten years from the last entry. Banks must keep audit and accounting support data six years and produce it immediately on demand. The ceiling: credit-reporting data may only show the last five years, dropping to two years once the debt is paid.High confidence
What happens when something goes wrong?: There is no general duty to report a data breach in Argentina, checked on 18 August 2026 - the privacy law has no deadline and the regulator's security rules are recommendations, not commands. Finance is the exception and the clock is brutal: banks and registered payment firms must tell the banking supervisor within one hour of an incident happening or being spotted, keep sending updates, and file a closing report within five days.High confidence
What's the trap?: Five things bite people. Answer times are very short: ten days for an access request and five working days to correct or delete. The maximum fine is one hundred thousand pesos, about seventy US dollars, so the real risk is a shutdown order or a criminal case, not the fine. Databases still have to be registered. Publishing a map of Argentina needs government approval first. And a bank cannot run its technology and security management from abroad.High confidence
What's about to change?: Nothing is scheduled to replace the privacy law. A reform bill went to Congress in 2023 and never became law; the regulator is still campaigning for a new one. The dated thing to watch is government cybersecurity: public bodies have about 180 days from 13 May 2026 to have contingency plans and a working alternative data centre, which lands around November 2026, and a new national cybersecurity centre started issuing rules in 2026.Medium confidence
Hardest industry wall: None found.

The eight framework questions answered for each selected country
Question	Hong Kong SARChecked 18 August 2026	ArgentinaChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Yes, with paperwork Work: Medium Enforcement: Active
In one paragraph	Hong Kong's privacy law contains a cross-border transfer ban that has never been switched on. It was written in 1995 and, thirty years later, still has no start date. So under the general law you can send personal data anywhere with no paperwork at all. The privacy regulator is busy and prosecutes people, but it cannot fine you directly.	Argentina lets personal data leave the country, but only on paper terms it sets. You either send it to a country the regulator has approved, or you sign the regulator's own model contract with the receiver. No industry has to keep data inside Argentina. Fines are tiny in dollars, but the regulator can order a database shut down, and some misuse is a crime.
The catch	The free-for-all stops at three doors. Licensed securities and futures firms need written permission from the markets regulator before their records live only on servers outside Hong Kong. Government departments are told not to put sensitive or personal information on public cloud at all. And data coming the other way, from mainland China into Hong Kong, is tightly controlled by mainland law, not by Hong Kong law - that is the wall most companies actually hit.	There is no data-residency wall in Argentina, but four sector rules still catch people out. Banks and payment firms must run their technology and security management from inside Argentina, must tell the banking supervisor before they outsource, and must report a cyber incident within one hour. Government bodies must have a working backup data centre by late 2026. And nobody may publish a map showing Argentine territory without the national mapping agency's prior approval.
Does this apply to me?	Yes, it can reach you with no office in Hong Kong. The privacy law bites on whoever controls the collection, holding, use or processing of personal data in or from Hong Kong, so a foreign company running a Hong Kong-facing service is caught. There is no revenue or headcount threshold to fall below, no register to join, and no requirement to appoint a local representative. The anti-doxxing powers go further still: the regulator can order an overseas platform to take material down.High confidence	The main privacy law is Ley 25.326, passed in 2000. It covers personal data held in any file or database in Argentina, public or private. There is no size threshold, no revenue threshold, and no duty to appoint a local representative. The law does not clearly say it reaches a foreign company with no presence in Argentina, and in practice the regulator has acted against local subsidiaries of global firms rather than against foreign entities directly.High confidence
Can the data leave the country?	Under the general privacy law, yes - freely, with nothing to sign. The one section that would have restricted transfers abroad was written into the law in 1995 and has never been brought into operation, so today there is no legal control on personal data leaving Hong Kong. Industry rules are where the real limits sit, and there are fewer of them than people expect: the securities regulator is the main one, and government departments have their own restriction.High confidence	Yes, with paperwork. The rule is that personal data may not go to a country that does not protect it well enough. The regulator publishes a list of countries it accepts, and for everywhere else you sign its model contract with the receiver. We looked for industries that must keep data inside Argentina - banking, payments, insurance, securities, health, telecoms, government cloud and mapping - and found none as of 18 August 2026.High confidence
What do I have to do to send it abroad?	Nothing. There is no approval to seek, no standard contract to sign and no government list to check before personal data leaves Hong Kong. The model on paper is an allowlist - the regulator would publish a list of approved destinations - but because the section was never switched on, that list has never been issued and is empty. The regulator does publish a voluntary guide and encourages firms to build the safeguards now, but that is advice, not law.High confidence	The model is an approved-destinations list, and it is populated today with about a dozen places, including the whole European Union. If your destination is not on it, use the regulator's published model contract - two versions, one for handing data to another company that decides how to use it and one for a supplier processing it for you. Using the published wording needs no permission. If you change the wording, you must file the contract with the regulator within 30 days of signing.High confidence
Who enforces this — and are they actually working?	The Privacy Commissioner for Personal Data, and it is genuinely busy. By the end of December 2025 it had issued 2,104 orders to 57 online platforms to take down 33,743 doxxing messages, opened 519 criminal investigations and arrested 81 people. But there is a catch that changes the risk picture completely: the Commissioner cannot impose a fine for breaking the privacy principles. It serves a notice telling you to fix the problem, and only ignoring that notice is a crime.High confidence	The Agency for Access to Public Information, known by its Spanish initials AAIP, enforces both privacy and freedom of information. It is real and working: it has a named head, it publishes a register of final penalties that was updated on 3 July 2026, it opened a public investigation into debt-collection calls in April 2026, and it chaired an international data-protection committee in July 2026. Its 244 final penalties are mostly small, and more than half are for calling people on the do-not-call list.High confidence
How long must I keep it, and when must I delete it?	There is a hard ceiling and almost no floor in the privacy law itself. You must erase personal data once it is no longer needed for the purpose you collected it for, and failing to do so is a criminal offence carrying a fine of up to HK$10,000 (about $1,300). The privacy law sets no minimum keeping periods; those come from tax, company and anti-money-laundering law instead. Where the two pull against each other, the specific keeping duty in the other law wins, and you delete once it expires.Medium confidence	Argentina has strong floors and one hard ceiling. Anti-money-laundering rules make banks, insurers, crypto firms, accountants and estate agents keep transaction records and customer files for at least ten years. Clinical records must be kept ten years from the last entry. Banks must keep audit and accounting support data six years and produce it immediately on demand. The ceiling: credit-reporting data may only show the last five years, dropping to two years once the debt is paid.High confidence
What happens when something goes wrong?	For a normal data breach there is no deadline, because there is no duty. Telling the Privacy Commissioner about a breach is voluntary in Hong Kong - the regulator asks you to do it as good practice and gives you a form, but no law compels it. That is unusual and it is changing: since 1 January 2026 operators of designated critical infrastructure must report computer-system security incidents, so those firms now have a real clock while everyone else has none.High confidence	There is no general duty to report a data breach in Argentina, checked on 18 August 2026 - the privacy law has no deadline and the regulator's security rules are recommendations, not commands. Finance is the exception and the clock is brutal: banks and registered payment firms must tell the banking supervisor within one hour of an incident happening or being spotted, keep sending updates, and file a closing report within five days.High confidence
What's the trap?	Five things that catch people out. First, marketing mistakes are crimes here, not fines - using someone's data for direct marketing without the right consent can mean five years in prison. Second, the regulator cannot fine you, so people assume the risk is low and miss the criminal exposure entirely. Third, Hong Kong sets no age at which a child can consent, so there is no simple number to code into a sign-up flow. Fourth, licensed securities firms need written permission before their records live only on overseas servers, and two named people who live in Hong Kong must be able to unlock them. Fifth, the dormant transfer section, if ever switched on, would also catch data moving between two foreign countries when a Hong Kong company controls it.Medium confidence	Five things bite people. Answer times are very short: ten days for an access request and five working days to correct or delete. The maximum fine is one hundred thousand pesos, about seventy US dollars, so the real risk is a shutdown order or a criminal case, not the fine. Databases still have to be registered. Publishing a map of Argentina needs government approval first. And a bank cannot run its technology and security management from abroad.High confidence
What's about to change?	Nothing is scheduled to land in the next twelve months that we could confirm. The critical infrastructure security law already started on 1 January 2026, and the government's guideline for generative artificial intelligence was revised in December 2025. The thing to watch is not a new bill. It is a switch the government has held for thirty years: the cross-border transfer section can be brought into force by a simple commencement notice, with no consultation and no new vote.Medium confidence	Nothing is scheduled to replace the privacy law. A reform bill went to Congress in 2023 and never became law; the regulator is still campaigning for a new one. The dated thing to watch is government cybersecurity: public bodies have about 180 days from 13 May 2026 to have contingency plans and a working alternative data centre, which lands around November 2026, and a new national cybersecurity centre started issuing rules in 2026.Medium confidence
Hardest industry wall	None found.	None found.