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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.

South KoreaChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Aggressive

In one paragraph: South Korea's privacy law bans sending personal data abroad unless you have one of five grounds. The usual one is a separate consent, ticked apart from every other consent. Since September 2025 the 30 European countries need no extra paperwork. But banking, health records, government cloud and detailed maps have hard walls no consent can unlock, and the regulator fines foreign companies often.
The catch: The 'get consent and send it' headline stops being true the moment you touch six areas: bank and payment systems, financial customers' national ID numbers, hospital records, government cloud, detailed mapping data, and personal location services. In those areas the data or the machine holding it must physically sit in South Korea, and in the government cloud case so must the people who run it.
Does this apply to me?: Yes. The regulator fines companies with no Korean office. In July 2026 it fined TikTok's Singapore company and two Apple companies based in Ireland and Singapore for collecting Korean users' data and sending it abroad without a proper legal basis. If your worldwide revenue was 1 trillion won (about $720 million) or more last year, or you held data on an average of 1 million or more people in Korea per day over the last three months of last year, you must appoint a representative in Korea. Since April 2026, if you already own or control a Korean company, that Korean company has to be the representative.High confidence
Can the data leave the country?: In general yes, but only if you have one of five grounds, and the usual one is a separate consent that the person ticks apart from every other consent. Since September 2025 you can also send data to the 27 European Union countries plus Norway, Iceland and Liechtenstein with no extra step at all, because the regulator has formally accepted their protection as equal to Korea's. That is the only such list, and no other country is on it. Six industries override all of this and are covered below.High confidence
What do I have to do to send it abroad?: Korea does not police the destination. It polices your paperwork. There is no banned-country list and no approval application to file: you pick one of the five grounds, and for most companies that means asking each person for a separate transfer consent that lists what goes, where, to whom, for how long and how to refuse. The one destination list that exists is a positive one, and it holds exactly 30 countries: the European Union plus Norway, Iceland and Liechtenstein. Send data anywhere else and you also have to keep security measures, a complaints route and a dispute process in place, and write the transfer into your contract with the recipient.High confidence
Who enforces this — and are they actually working?: The Personal Information Protection Commission, chaired by Song Kyoung-hee, and it is one of the busiest privacy regulators in the world right now. In July 2026 alone it fined the telecoms company KT about 54 billion won (roughly $39 million) over a data breach, fined TikTok about 10.3 billion won (roughly $7.4 million) and Apple about 252 million won (roughly $180,000). It referred KT to prosecutors for obstructing the investigation and asked police to investigate LG U+ for destroying a server before the inquiry started. Finance is separately policed by the Financial Services Commission and the Financial Supervisory Service; health by the health ministry; maps by an inter-agency committee that includes the intelligence service.High confidence
How long must I keep it, and when must I delete it?: Two forces pull in opposite directions. The ceiling: you must destroy personal data without delay once you no longer need it, and destroy it so it cannot be recovered. The floor: other laws make you keep things. An online seller must keep advertising records for 6 months, complaint and dispute records for 3 years, and contract, cancellation, payment and delivery records for 5 years. Almost everyone must keep system access logs for at least 1 year, and 2 years if the system holds data on 50,000 or more people, holds national ID numbers or sensitive data, or belongs to a licensed telecoms carrier. When the two clash, the keeping rule wins, but you must store that data separately from everything else.High confidence
What happens when something goes wrong?: Count two clocks, and in telecoms and finance a third. Under the privacy law you have 72 hours to tell the affected people, and a separate 72 hours to report to the Commission or to the Korea Internet and Security Agency. The reporting clock starts if 1,000 or more people are affected, or if any sensitive data or national ID numbers leaked, or if the cause was someone breaking in from outside. Separately, an internet service provider must report a cyber incident to the science ministry or the same agency immediately. A hospital must also tell the health ministry about a medical-records incident.High confidence
What's the trap?: Five things that will cost you a weekend. One: the children's age line is 14, not 13 or 16, and processing an under-14's data without a parent's consent is a crime punishable by up to five years in prison, not just a fine. Two: hiding or destroying material during a regulator's inspection is itself a crime, and the regulator used it in July 2026. Three: stripping names out of a dataset does not free it. Four: a bank's Korean customers' national ID numbers may not leave the country at all, and any offshore processing of customers' financial transaction data needs a report to the supervisor 30 business days before work starts. Five: if you want to run a personal location service you must be a corporation and be registered, so you cannot serve Korea from abroad with no entity.High confidence
What's about to change?: The privacy regulator started rewriting the rulebook for artificial intelligence. It set up a reform task force on 30 July 2026, ran a public suggestion window from 6 to 31 August 2026, and plans to publish the direction of reform before the end of 2026. Consent-based rules and the block on sending pseudonymised data abroad for research are both explicitly on the table. Separately, Apple's request to export detailed Korean map data has been pending since its deadline was extended in December 2025, and Google's equivalent request was granted in February 2026 on strict conditions, so the mapping picture can move again at any time.High confidence
Hardest industry wall: Banking — 전자금융감독규정 (Regulation on Supervision of Electronic Financial Transactions)
Finance — 금융회사의 정보처리 업무 위탁에 관한 규정 (Regulation on Outsourcing of Data Processing Business by Financial Companies)
Health and social care — 전자의무기록의 관리·보존에 필요한 시설과 장비에 관한 기준 (Standards for the Facilities and Equipment Required to Manage and Preserve Electronic Medical Records)
Government — 클라우드컴퓨팅서비스 보안인증에 관한 고시 (Notice on Security Certification of Cloud Computing Services)
Mapping and location — 공간정보의 구축 및 관리 등에 관한 법률 (Act on the Establishment and Management of Spatial Data)

The eight framework questions answered for each selected country
Question	Hong Kong SARChecked 18 August 2026	South KoreaChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Depends on your industry Work: High Enforcement: Aggressive
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.	South Korea's privacy law bans sending personal data abroad unless you have one of five grounds. The usual one is a separate consent, ticked apart from every other consent. Since September 2025 the 30 European countries need no extra paperwork. But banking, health records, government cloud and detailed maps have hard walls no consent can unlock, and the regulator fines foreign companies often.
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 'get consent and send it' headline stops being true the moment you touch six areas: bank and payment systems, financial customers' national ID numbers, hospital records, government cloud, detailed mapping data, and personal location services. In those areas the data or the machine holding it must physically sit in South Korea, and in the government cloud case so must the people who run it.
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. The regulator fines companies with no Korean office. In July 2026 it fined TikTok's Singapore company and two Apple companies based in Ireland and Singapore for collecting Korean users' data and sending it abroad without a proper legal basis. If your worldwide revenue was 1 trillion won (about $720 million) or more last year, or you held data on an average of 1 million or more people in Korea per day over the last three months of last year, you must appoint a representative in Korea. Since April 2026, if you already own or control a Korean company, that Korean company has to be the representative.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, but only if you have one of five grounds, and the usual one is a separate consent that the person ticks apart from every other consent. Since September 2025 you can also send data to the 27 European Union countries plus Norway, Iceland and Liechtenstein with no extra step at all, because the regulator has formally accepted their protection as equal to Korea's. That is the only such list, and no other country is on it. Six industries override all of this and are covered below.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	Korea does not police the destination. It polices your paperwork. There is no banned-country list and no approval application to file: you pick one of the five grounds, and for most companies that means asking each person for a separate transfer consent that lists what goes, where, to whom, for how long and how to refuse. The one destination list that exists is a positive one, and it holds exactly 30 countries: the European Union plus Norway, Iceland and Liechtenstein. Send data anywhere else and you also have to keep security measures, a complaints route and a dispute process in place, and write the transfer into your contract with the recipient.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 Personal Information Protection Commission, chaired by Song Kyoung-hee, and it is one of the busiest privacy regulators in the world right now. In July 2026 alone it fined the telecoms company KT about 54 billion won (roughly $39 million) over a data breach, fined TikTok about 10.3 billion won (roughly $7.4 million) and Apple about 252 million won (roughly $180,000). It referred KT to prosecutors for obstructing the investigation and asked police to investigate LG U+ for destroying a server before the inquiry started. Finance is separately policed by the Financial Services Commission and the Financial Supervisory Service; health by the health ministry; maps by an inter-agency committee that includes the intelligence service.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	Two forces pull in opposite directions. The ceiling: you must destroy personal data without delay once you no longer need it, and destroy it so it cannot be recovered. The floor: other laws make you keep things. An online seller must keep advertising records for 6 months, complaint and dispute records for 3 years, and contract, cancellation, payment and delivery records for 5 years. Almost everyone must keep system access logs for at least 1 year, and 2 years if the system holds data on 50,000 or more people, holds national ID numbers or sensitive data, or belongs to a licensed telecoms carrier. When the two clash, the keeping rule wins, but you must store that data separately from everything else.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 two clocks, and in telecoms and finance a third. Under the privacy law you have 72 hours to tell the affected people, and a separate 72 hours to report to the Commission or to the Korea Internet and Security Agency. The reporting clock starts if 1,000 or more people are affected, or if any sensitive data or national ID numbers leaked, or if the cause was someone breaking in from outside. Separately, an internet service provider must report a cyber incident to the science ministry or the same agency immediately. A hospital must also tell the health ministry about a medical-records incident.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. One: the children's age line is 14, not 13 or 16, and processing an under-14's data without a parent's consent is a crime punishable by up to five years in prison, not just a fine. Two: hiding or destroying material during a regulator's inspection is itself a crime, and the regulator used it in July 2026. Three: stripping names out of a dataset does not free it. Four: a bank's Korean customers' national ID numbers may not leave the country at all, and any offshore processing of customers' financial transaction data needs a report to the supervisor 30 business days before work starts. Five: if you want to run a personal location service you must be a corporation and be registered, so you cannot serve Korea from abroad with no entity.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	The privacy regulator started rewriting the rulebook for artificial intelligence. It set up a reform task force on 30 July 2026, ran a public suggestion window from 6 to 31 August 2026, and plans to publish the direction of reform before the end of 2026. Consent-based rules and the block on sending pseudonymised data abroad for research are both explicitly on the table. Separately, Apple's request to export detailed Korean map data has been pending since its deadline was extended in December 2025, and Google's equivalent request was granted in February 2026 on strict conditions, so the mapping picture can move again at any time.High confidence
Hardest industry wall	None found.	Banking — 전자금융감독규정 (Regulation on Supervision of Electronic Financial Transactions) Finance — 금융회사의 정보처리 업무 위탁에 관한 규정 (Regulation on Outsourcing of Data Processing Business by Financial Companies) Health and social care — 전자의무기록의 관리·보존에 필요한 시설과 장비에 관한 기준 (Standards for the Facilities and Equipment Required to Manage and Preserve Electronic Medical Records) Government — 클라우드컴퓨팅서비스 보안인증에 관한 고시 (Notice on Security Certification of Cloud Computing Services) Mapping and location — 공간정보의 구축 및 관리 등에 관한 법률 (Act on the Establishment and Management of Spatial Data)