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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.

CroatiaChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: Croatia looks like an ordinary European Union country for privacy: data may leave once you have the right paperwork. But its accounting law is stricter than most people expect. A Croatian company's books and receipts may only be kept in Croatia or another European Union country. Public bodies must keep personal-data registers in Croatian data centres. The privacy regulator fines hard.
The catch: The relaxed European headline stops being true in four places. First, accounting: the books and supporting documents of any Croatian company may be kept outside Croatia only in another European Union member state, so a United States or United Kingdom cloud archive of your ledger is not lawful, and no contract or consent fixes it. Second, the public sector: since May 2025 state registers containing personal data must sit in data centres on Croatian soil, and state bodies must use the government's own Shared Services Centre. Third, health: health data must be processed inside Croatia's national health information infrastructure and exchanged through the central health system. Fourth, aerial imagery: you need one permission to photograph Croatia from the air and a second permission to use the pictures, and the Ministry of Defence screens them first.
Does this apply to me?: Yes. Croatia's rules reach a company with no office in the country. The European Union privacy rulebook applies to anyone who offers goods or services to people in Europe, or who watches what they do online. There is no revenue or headcount threshold. Croatia does not demand its own local representative on top of the Europe-wide one, which you may place in any European country.High confidence
Can the data leave the country?: Mostly yes, but with one nasty exception that catches everybody. Ordinary personal data can go abroad using the standard European transfer tools. Your accounting records cannot: Croatian law allows them to be kept outside Croatia only in another European Union country. Health data, public-sector registers and aerial photographs each have their own separate walls.High confidence
What do I have to do to send it abroad?: For personal data, Croatia uses the European model. Some countries are pre-approved, and everywhere else you need a standard contract or a similar tool plus a risk check. The approved list is real and populated, and includes the United Kingdom, Japan, South Korea and Switzerland. For accounting records the model is different and much blunter: only European Union countries are allowed, and no paperwork buys you more.High confidence
Who enforces this — and are they actually working?: The main regulator is the Personal Data Protection Agency, known as AZOP. It is fully staffed, it hires more people, and it is one of the busiest fining bodies in central Europe for its size. It issued 13 fines totalling about 6.7 million euros (roughly 7.3 million dollars) in 2025, and 38 fines the year before. The cyber regulator, the National Cyber Security Centre, is also up and running.High confidence
How long must I keep it, and when must I delete it?: Croatia has strong minimum keeping periods and a few hard maximums. Ledgers and the documents behind them must be kept at least eleven years; payroll lists six years; the detailed wage and contribution records forever. Medical records run to ten years after the patient dies. Going the other way, camera footage must normally be deleted after six months.High confidence
What happens when something goes wrong?: There are at least two clocks and they run at different speeds. A personal data breach goes to the privacy regulator within 72 hours. A significant cyber incident goes to the cyber authority within 24 hours as an early warning, with a fuller report at 72 hours and a final report within 30 days. One incident can easily trigger both, and the 24-hour clock is the one that catches people out.High confidence
What's the trap?: Five things that are not in the summary. Your ledger cannot live on an American cloud. Children count as adults for online consent at 16, not 13. Using someone's personal data unlawfully is a crime, not just a fine. Genetic test results may never be used to price life insurance. And camera footage in an apartment building needs two thirds of the owners to agree.High confidence
What's about to change?: Two Croatian dates matter. Fines under the state information infrastructure law switch on 1 January 2027. Mandatory eInvoicing widens to smaller traders on the same day. Across Europe, cloud switching fees must fall to zero by 12 January 2027. The thing to watch is the challenge to the Europe-United States data deal, which is still valid but under real pressure.Medium confidence
Hardest industry wall: All industries — Zakon o računovodstvu
Government — Zakon o državnoj informacijskoj infrastrukturi
Health and social care — Zakon o podacima i informacijama u zdravstvu

The eight framework questions answered for each selected country
Question	Hong Kong SARChecked 18 August 2026	CroatiaChecked 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.	Croatia looks like an ordinary European Union country for privacy: data may leave once you have the right paperwork. But its accounting law is stricter than most people expect. A Croatian company's books and receipts may only be kept in Croatia or another European Union country. Public bodies must keep personal-data registers in Croatian data centres. The privacy regulator fines hard.
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 in four places. First, accounting: the books and supporting documents of any Croatian company may be kept outside Croatia only in another European Union member state, so a United States or United Kingdom cloud archive of your ledger is not lawful, and no contract or consent fixes it. Second, the public sector: since May 2025 state registers containing personal data must sit in data centres on Croatian soil, and state bodies must use the government's own Shared Services Centre. Third, health: health data must be processed inside Croatia's national health information infrastructure and exchanged through the central health system. Fourth, aerial imagery: you need one permission to photograph Croatia from the air and a second permission to use the pictures, and the Ministry of Defence screens them first.
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. Croatia's rules reach a company with no office in the country. The European Union privacy rulebook applies to anyone who offers goods or services to people in Europe, or who watches what they do online. There is no revenue or headcount threshold. Croatia does not demand its own local representative on top of the Europe-wide one, which you may place in any European country.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	Mostly yes, but with one nasty exception that catches everybody. Ordinary personal data can go abroad using the standard European transfer tools. Your accounting records cannot: Croatian law allows them to be kept outside Croatia only in another European Union country. Health data, public-sector registers and aerial photographs each have their own separate walls.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	For personal data, Croatia uses the European model. Some countries are pre-approved, and everywhere else you need a standard contract or a similar tool plus a risk check. The approved list is real and populated, and includes the United Kingdom, Japan, South Korea and Switzerland. For accounting records the model is different and much blunter: only European Union countries are allowed, and no paperwork buys you more.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 main regulator is the Personal Data Protection Agency, known as AZOP. It is fully staffed, it hires more people, and it is one of the busiest fining bodies in central Europe for its size. It issued 13 fines totalling about 6.7 million euros (roughly 7.3 million dollars) in 2025, and 38 fines the year before. The cyber regulator, the National Cyber Security Centre, is also up and running.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	Croatia has strong minimum keeping periods and a few hard maximums. Ledgers and the documents behind them must be kept at least eleven years; payroll lists six years; the detailed wage and contribution records forever. Medical records run to ten years after the patient dies. Going the other way, camera footage must normally be deleted after six months.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 are at least two clocks and they run at different speeds. A personal data breach goes to the privacy regulator within 72 hours. A significant cyber incident goes to the cyber authority within 24 hours as an early warning, with a fuller report at 72 hours and a final report within 30 days. One incident can easily trigger both, and the 24-hour clock is the one that catches people out.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 are not in the summary. Your ledger cannot live on an American cloud. Children count as adults for online consent at 16, not 13. Using someone's personal data unlawfully is a crime, not just a fine. Genetic test results may never be used to price life insurance. And camera footage in an apartment building needs two thirds of the owners to agree.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	Two Croatian dates matter. Fines under the state information infrastructure law switch on 1 January 2027. Mandatory eInvoicing widens to smaller traders on the same day. Across Europe, cloud switching fees must fall to zero by 12 January 2027. The thing to watch is the challenge to the Europe-United States data deal, which is still valid but under real pressure.Medium confidence
Hardest industry wall	None found.	All industries — Zakon o računovodstvu Government — Zakon o državnoj informacijskoj infrastrukturi Health and social care — Zakon o podacima i informacijama u zdravstvu