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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.

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)

The eight framework questions answered for each selected country
Question	Hong Kong SARChecked 18 August 2026	GreeceChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Depends on your industry Work: High 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.	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 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.	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 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	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?	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	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?	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	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?	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	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?	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	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?	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	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 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 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?	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	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	None found.	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)