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

Countries

IndonesiaChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Waking up

In one paragraph: Indonesia's general privacy law lets data leave if the destination protects it about as well as Indonesia does, or you use strong safeguards, or the person agrees. Money and health are walled off. Banks, payment firms, insurers and non-bank lenders must run their systems on Indonesian soil unless the financial regulator says otherwise, and medical records must sit with a local storage provider.
The catch: The relaxed headline is true only until you touch banking, payments, insurance and other non-bank finance, electronic medical records, or public-sector systems. In those areas the servers themselves must be in Indonesia, and moving them out needs a written permission that the banking regulator may take three months to grant. The general privacy watchdog looks quiet; the financial regulators are not.
Does this apply to me?: Yes. The privacy law follows the data, not the office. It covers any organisation, inside or outside Indonesia, whose handling of personal data has legal effects in Indonesia or affects people in Indonesia. There is no size or revenue cut-off to fall below. An organisation with no presence in the country is expected to name a representative in Indonesia, and any online service used by Indonesians is also expected to register with the digital ministry, which can order internet providers to block services that do not.Medium confidence
Can the data leave the country?: In general yes, with homework. You must be able to show the destination protects personal data at a level at least equal to Indonesia's, or put binding safeguards in place, or get the person's clear agreement. That general answer stops at the door of finance, health and government. Banks, payment providers, insurers and other non-bank financial firms must keep their systems in Indonesian data centres and back-up centres, and can only go offshore with written regulator permission. Electronic medical records must be stored with a provider that has storage facilities inside Indonesia.High confidence
What do I have to do to send it abroad?: There is no published list of approved countries and no official standard contract to sign. Under the general law you assess the destination yourself, write down why it is safe enough, and keep that evidence. In finance the model is completely different: you need a real permission from the regulator before the systems move, and the banking regulator allows itself up to three months to answer once your paperwork is complete.Medium confidence
Who enforces this — and are they actually working?: It depends which rule you break. The privacy law's own watchdog is the weak spot: the law says a supervisory body must be set up by the President, and we found no government source showing it is staffed and issuing decisions as of 18 August 2026. Day to day the digital ministry handles complaints, registration and blocking. The financial regulators are a different story — the Financial Services Authority and the central bank are plainly working, and the Authority issued new binding rules as recently as July 2026.Medium confidence
How long must I keep it, and when must I delete it?: There is a floor and a ceiling and they collide. The hardest floor is health: a hospital or clinic must keep an electronic medical record for at least 25 years after the patient's last visit. Company and tax paperwork must also be kept for years. The ceiling comes from the privacy law, which says personal data must be erased once the purpose is finished, the retention period ends, or the person withdraws consent. Where they clash, the specific keeping rule wins, so a patient asking for deletion does not defeat the 25-year rule.High confidence
What happens when something goes wrong?: Count at least three clocks, and the privacy one is not the fastest. Under the privacy law you have 72 hours to tell the affected people and the regulator about a personal data breach. If you are a bank, you must send the financial regulator a first alert within 24 hours of learning about a serious technology incident, and a full incident report within five working days. Other financial firms, such as insurers and lenders, have five working days. Miss the 24-hour one and the fact that you met the 72-hour one will not help you.High confidence
What's the trap?: Five things that ruin weekends. (1) In finance the wall is a permission, not a contract — moving systems abroad needs a regulator licence and the banking regulator gives itself up to three months to decide, so cloud migrations must be planned around that. (2) In health your cloud provider must have storage facilities in Indonesia, and the Ministry of Health can demand access to the whole medical record. (3) The 25-year medical record rule beats a patient's deletion request. (4) The privacy law carries prison sentences, not just fines, so directors are personally exposed. (5) A foreign company with no office still needs a named representative in Indonesia, and a consumer service that is not registered with the digital ministry can be blocked at the internet level.Medium confidence
What's about to change?: One dated change is certain: from 1 September 2026 trading in digital financial assets, including crypto, runs under the financial regulator's new rulebook, so anyone in that business should re-check where its servers and records must sit. Two things are still pending as far as we could verify: the detailed implementing regulation under the privacy law, and the presidential decision setting up the privacy watchdog itself. Both could land without warning.Medium confidence
Hardest industry wall: Banking — Peraturan Otoritas Jasa Keuangan Nomor 11/POJK.03/2022 tentang Penyelenggaraan Teknologi Informasi oleh Bank Umum
Payments — Peraturan Bank Indonesia Nomor 23/6/PBI/2021 tentang Penyedia Jasa Pembayaran
Insurance — Peraturan Otoritas Jasa Keuangan Nomor 4/POJK.05/2021 tentang Penerapan Manajemen Risiko dalam Penggunaan Teknologi Informasi oleh Lembaga Jasa Keuangan Nonbank
Health and social care — Peraturan Menteri Kesehatan Nomor 24 Tahun 2022 tentang Rekam Medis
Government — Peraturan Pemerintah Nomor 71 Tahun 2019 tentang Penyelenggaraan Sistem dan Transaksi Elektronik
Mapping and location — Undang-Undang Nomor 4 Tahun 2011 tentang Informasi Geospasial

TurkeyChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: Turkey lets personal data leave, but only after you build the paperwork yourself. The regulator has never declared a single country safe, so the approved-destination list is empty. Most companies use a government-published standard contract and must file it within five working days. The regulator is busy: it fined 876 organisations in 2025.
The catch: The general rule is 'paperwork, then you may send it'. That stops being true the moment you touch payments, banking, telecoms networks, public-sector systems or critical infrastructure. Payment and electronic money firms must keep their systems, their backups and their data inside Turkey, and may only use cloud providers the central bank has approved by name.
Does this apply to me?: Yes. A company with no office in Turkey is still caught, and it is caught harder than a local one. Any organisation based outside Turkey that decides why and how Turkish people's data is used must appoint a representative inside Turkey and sign up to the public register of data controllers before it starts processing. That representative has to be a company set up in Turkey or a Turkish citizen. Turkish small businesses can escape the register if they have fewer than 50 staff and a balance sheet under 100 million lira, but there is no such let-off for foreign companies.High confidence
Can the data leave the country?: It depends entirely on your industry, which is why Turkey is rated 'sectoral'. Under the general privacy law data may leave, but only after you put an approved safeguard in place, because the regulator has not yet declared any country safe. In payments and banking the answer flips to no: systems, backups and data have to sit inside Turkey. Public bodies, critical infrastructure, telecoms networks and health records all carry their own extra restrictions on top.High confidence
What do I have to do to send it abroad?: The model is an approved-destination list, and the list is empty. Nobody can rely on their country being blessed, so almost everyone uses one of the safeguards instead. The usual route is signing one of four standard contracts the regulator publishes, then telling the regulator within five working days of signing. Group companies can instead get binding corporate rules approved, and there is a permission route for bespoke undertakings, but that route almost always fails.High confidence
Who enforces this — and are they actually working?: The Personal Data Protection Authority, and it is fully up and running. In 2025 its board met 42 times, took 2,528 decisions, handled 12,512 complaints and fined 876 organisations a combined 352.5 million lira, which is roughly 8 million US dollars. It publishes named breach announcements most weeks. Financial, telecoms and insurance regulators enforce their own rules alongside it, and a new Cybersecurity Directorate has taken over the national cyber incident centre.High confidence
How long must I keep it, and when must I delete it?: Both directions apply, and the ceiling is unusual. Turkey does not give you a fixed number of months to delete by. Instead, once your reason for holding data runs out, you must erase it at your next scheduled clear-out, and any organisation on the public register has to publish a written retention and destruction policy setting those dates. The floor comes from ordinary commercial and tax law, which forces you to keep books and invoices for years.Medium confidence
What happens when something goes wrong?: There are at least three clocks. The privacy one is 72 hours: from the moment you learn that data has been taken unlawfully, you have three days to tell the Personal Data Protection Board, and you must tell the affected people as soon as you reasonably can. If you miss the 72 hours you must still report and explain why you were late. Companies based abroad have to report too, if people in Turkey are affected.High confidence
What's the trap?: Five things bite people. One: most fines are for paperwork, not privacy. Two thirds of the organisations fined in 2025 were punished for the public register, not for mishandling anyone's data. Two: the bespoke permission route for sending data abroad is close to a dead end, with 76 of 89 applications refused in 2025. Three: filing your standard contract invites inspection rather than closing the file. Four: your representative in Turkey must be Turkish. Five: no country is on the safe list, so there is no shortcut.High confidence
What's about to change?: Two dated items and one direction of travel. Retailers running loyalty cards have until 28 February 2027 to build a way of checking that the person at the till really owns the card, after the regulator extended the original deadline in July 2026. Public bodies are working to a July 2026 ruling on what they may publish online. And the government is pushing openly on data sovereignty, with the President chairing a cyber security meeting in May 2026 that treated data as a strategic asset.High confidence
Hardest industry wall: Payments — Odeme ve Elektronik Para Kuruluslarinin Bilgi Sistemleri ile Odeme Hizmeti Saglayicilarinin Odeme Hizmetleri Alanindaki Veri Paylasim Servislerine Iliskin Teblig
Banking — Bankalarin Bilgi Sistemleri ve Elektronik Bankacilik Hizmetleri Hakkinda Yonetmelik
Government — 2019/12 sayili Bilgi ve Iletisim Guvenligi Tedbirleri Genelgesi ve Bilgi ve Iletisim Guvenligi Rehberi

The eight framework questions answered for each selected country
Question	IndonesiaChecked 18 August 2026	TurkeyChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Waking up	Depends on your industry Work: High Enforcement: Active
In one paragraph	Indonesia's general privacy law lets data leave if the destination protects it about as well as Indonesia does, or you use strong safeguards, or the person agrees. Money and health are walled off. Banks, payment firms, insurers and non-bank lenders must run their systems on Indonesian soil unless the financial regulator says otherwise, and medical records must sit with a local storage provider.	Turkey lets personal data leave, but only after you build the paperwork yourself. The regulator has never declared a single country safe, so the approved-destination list is empty. Most companies use a government-published standard contract and must file it within five working days. The regulator is busy: it fined 876 organisations in 2025.
The catch	The relaxed headline is true only until you touch banking, payments, insurance and other non-bank finance, electronic medical records, or public-sector systems. In those areas the servers themselves must be in Indonesia, and moving them out needs a written permission that the banking regulator may take three months to grant. The general privacy watchdog looks quiet; the financial regulators are not.	The general rule is 'paperwork, then you may send it'. That stops being true the moment you touch payments, banking, telecoms networks, public-sector systems or critical infrastructure. Payment and electronic money firms must keep their systems, their backups and their data inside Turkey, and may only use cloud providers the central bank has approved by name.
Does this apply to me?	Yes. The privacy law follows the data, not the office. It covers any organisation, inside or outside Indonesia, whose handling of personal data has legal effects in Indonesia or affects people in Indonesia. There is no size or revenue cut-off to fall below. An organisation with no presence in the country is expected to name a representative in Indonesia, and any online service used by Indonesians is also expected to register with the digital ministry, which can order internet providers to block services that do not.Medium confidence	Yes. A company with no office in Turkey is still caught, and it is caught harder than a local one. Any organisation based outside Turkey that decides why and how Turkish people's data is used must appoint a representative inside Turkey and sign up to the public register of data controllers before it starts processing. That representative has to be a company set up in Turkey or a Turkish citizen. Turkish small businesses can escape the register if they have fewer than 50 staff and a balance sheet under 100 million lira, but there is no such let-off for foreign companies.High confidence
Can the data leave the country?	In general yes, with homework. You must be able to show the destination protects personal data at a level at least equal to Indonesia's, or put binding safeguards in place, or get the person's clear agreement. That general answer stops at the door of finance, health and government. Banks, payment providers, insurers and other non-bank financial firms must keep their systems in Indonesian data centres and back-up centres, and can only go offshore with written regulator permission. Electronic medical records must be stored with a provider that has storage facilities inside Indonesia.High confidence	It depends entirely on your industry, which is why Turkey is rated 'sectoral'. Under the general privacy law data may leave, but only after you put an approved safeguard in place, because the regulator has not yet declared any country safe. In payments and banking the answer flips to no: systems, backups and data have to sit inside Turkey. Public bodies, critical infrastructure, telecoms networks and health records all carry their own extra restrictions on top.High confidence
What do I have to do to send it abroad?	There is no published list of approved countries and no official standard contract to sign. Under the general law you assess the destination yourself, write down why it is safe enough, and keep that evidence. In finance the model is completely different: you need a real permission from the regulator before the systems move, and the banking regulator allows itself up to three months to answer once your paperwork is complete.Medium confidence	The model is an approved-destination list, and the list is empty. Nobody can rely on their country being blessed, so almost everyone uses one of the safeguards instead. The usual route is signing one of four standard contracts the regulator publishes, then telling the regulator within five working days of signing. Group companies can instead get binding corporate rules approved, and there is a permission route for bespoke undertakings, but that route almost always fails.High confidence
Who enforces this — and are they actually working?	It depends which rule you break. The privacy law's own watchdog is the weak spot: the law says a supervisory body must be set up by the President, and we found no government source showing it is staffed and issuing decisions as of 18 August 2026. Day to day the digital ministry handles complaints, registration and blocking. The financial regulators are a different story — the Financial Services Authority and the central bank are plainly working, and the Authority issued new binding rules as recently as July 2026.Medium confidence	The Personal Data Protection Authority, and it is fully up and running. In 2025 its board met 42 times, took 2,528 decisions, handled 12,512 complaints and fined 876 organisations a combined 352.5 million lira, which is roughly 8 million US dollars. It publishes named breach announcements most weeks. Financial, telecoms and insurance regulators enforce their own rules alongside it, and a new Cybersecurity Directorate has taken over the national cyber incident centre.High confidence
How long must I keep it, and when must I delete it?	There is a floor and a ceiling and they collide. The hardest floor is health: a hospital or clinic must keep an electronic medical record for at least 25 years after the patient's last visit. Company and tax paperwork must also be kept for years. The ceiling comes from the privacy law, which says personal data must be erased once the purpose is finished, the retention period ends, or the person withdraws consent. Where they clash, the specific keeping rule wins, so a patient asking for deletion does not defeat the 25-year rule.High confidence	Both directions apply, and the ceiling is unusual. Turkey does not give you a fixed number of months to delete by. Instead, once your reason for holding data runs out, you must erase it at your next scheduled clear-out, and any organisation on the public register has to publish a written retention and destruction policy setting those dates. The floor comes from ordinary commercial and tax law, which forces you to keep books and invoices for years.Medium confidence
What happens when something goes wrong?	Count at least three clocks, and the privacy one is not the fastest. Under the privacy law you have 72 hours to tell the affected people and the regulator about a personal data breach. If you are a bank, you must send the financial regulator a first alert within 24 hours of learning about a serious technology incident, and a full incident report within five working days. Other financial firms, such as insurers and lenders, have five working days. Miss the 24-hour one and the fact that you met the 72-hour one will not help you.High confidence	There are at least three clocks. The privacy one is 72 hours: from the moment you learn that data has been taken unlawfully, you have three days to tell the Personal Data Protection Board, and you must tell the affected people as soon as you reasonably can. If you miss the 72 hours you must still report and explain why you were late. Companies based abroad have to report too, if people in Turkey are affected.High confidence
What's the trap?	Five things that ruin weekends. (1) In finance the wall is a permission, not a contract — moving systems abroad needs a regulator licence and the banking regulator gives itself up to three months to decide, so cloud migrations must be planned around that. (2) In health your cloud provider must have storage facilities in Indonesia, and the Ministry of Health can demand access to the whole medical record. (3) The 25-year medical record rule beats a patient's deletion request. (4) The privacy law carries prison sentences, not just fines, so directors are personally exposed. (5) A foreign company with no office still needs a named representative in Indonesia, and a consumer service that is not registered with the digital ministry can be blocked at the internet level.Medium confidence	Five things bite people. One: most fines are for paperwork, not privacy. Two thirds of the organisations fined in 2025 were punished for the public register, not for mishandling anyone's data. Two: the bespoke permission route for sending data abroad is close to a dead end, with 76 of 89 applications refused in 2025. Three: filing your standard contract invites inspection rather than closing the file. Four: your representative in Turkey must be Turkish. Five: no country is on the safe list, so there is no shortcut.High confidence
What's about to change?	One dated change is certain: from 1 September 2026 trading in digital financial assets, including crypto, runs under the financial regulator's new rulebook, so anyone in that business should re-check where its servers and records must sit. Two things are still pending as far as we could verify: the detailed implementing regulation under the privacy law, and the presidential decision setting up the privacy watchdog itself. Both could land without warning.Medium confidence	Two dated items and one direction of travel. Retailers running loyalty cards have until 28 February 2027 to build a way of checking that the person at the till really owns the card, after the regulator extended the original deadline in July 2026. Public bodies are working to a July 2026 ruling on what they may publish online. And the government is pushing openly on data sovereignty, with the President chairing a cyber security meeting in May 2026 that treated data as a strategic asset.High confidence
Hardest industry wall	Banking — Peraturan Otoritas Jasa Keuangan Nomor 11/POJK.03/2022 tentang Penyelenggaraan Teknologi Informasi oleh Bank Umum Payments — Peraturan Bank Indonesia Nomor 23/6/PBI/2021 tentang Penyedia Jasa Pembayaran Insurance — Peraturan Otoritas Jasa Keuangan Nomor 4/POJK.05/2021 tentang Penerapan Manajemen Risiko dalam Penggunaan Teknologi Informasi oleh Lembaga Jasa Keuangan Nonbank Health and social care — Peraturan Menteri Kesehatan Nomor 24 Tahun 2022 tentang Rekam Medis Government — Peraturan Pemerintah Nomor 71 Tahun 2019 tentang Penyelenggaraan Sistem dan Transaksi Elektronik Mapping and location — Undang-Undang Nomor 4 Tahun 2011 tentang Informasi Geospasial	Payments — Odeme ve Elektronik Para Kuruluslarinin Bilgi Sistemleri ile Odeme Hizmeti Saglayicilarinin Odeme Hizmetleri Alanindaki Veri Paylasim Servislerine Iliskin Teblig Banking — Bankalarin Bilgi Sistemleri ve Elektronik Bankacilik Hizmetleri Hakkinda Yonetmelik Government — 2019/12 sayili Bilgi ve Iletisim Guvenligi Tedbirleri Genelgesi ve Bilgi ve Iletisim Guvenligi Rehberi