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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
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)