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

Countries

IrelandChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Aggressive

In one paragraph: Ireland follows Europe's rules, so personal data can leave the country once you have the right paperwork in place. But a handful of Irish laws force certain records to be kept physically in Ireland, and breaking those is a crime rather than a fine. Ireland's privacy regulator is one of the toughest in Europe: in 2025 it fined TikTok 530 million euro and ordered it to stop sending data to China.
The catch: The relaxed headline stops being true in four places. Trust and company service providers, and cheque-cashing firms, must keep their anti-money-laundering records at premises inside Ireland for six years, and failing to do so is a criminal offence carrying up to five years in prison. Every Irish company must keep accounting information and returns at a place in Ireland even when the books themselves sit on a foreign server. Health records and telephone and internet connection records each have their own separate rules on top.
Does this apply to me?: Yes. Ireland's data protection law reaches a company with no office in Ireland whenever it offers goods or services to people in Europe or watches what they do online. There is no revenue or headcount threshold to duck under. A company based outside Europe normally has to name a representative inside Europe who regulators and members of the public can write to.High confidence
Can the data leave the country?: In general, yes, with paperwork. Ireland does not have a general rule saying personal data must stay in the country. Sending it outside Europe is allowed once you use one of the approved legal routes. But several Irish laws quietly demand that particular records sit on Irish soil, and those override the friendly headline.High confidence
What do I have to do to send it abroad?: Ireland uses the European model. A destination outside Europe is off limits unless it is on the European Commission's approved list, or you put an approved safeguard in place first. The approved list is real and populated: it currently covers seventeen destinations, including the United Kingdom, Japan, South Korea, Switzerland and Brazil. The United States counts only for companies that have signed up to the European Union to United States Data Privacy Framework.High confidence
Who enforces this — and are they actually working?: The Data Protection Commission, and it is very much awake. It has three commissioners in post — Des Hogan as chairperson, Dale Sunderland and Niamh Sweeney — and it published its 2025 annual report on 30 June 2026. In 2025 it finished four large inquiries and imposed fines of just over 530 million euro (about 580 million US dollars), almost all of it on TikTok, which it also ordered to stop sending European user data to China.High confidence
How long must I keep it, and when must I delete it?: Both directions apply, and Ireland's floors are longer than most people expect. Anti-money-laundering customer records must be kept for at least five years. Company accounting records and returns must be kept for at least six years. Trust and company service providers and cheque-cashing firms must keep their records for six years and keep them in Ireland. Telephone and internet providers must keep subscriber details for one year.High confidence
What happens when something goes wrong?: Count three clocks, not one. You have 72 hours to tell the Data Protection Commission about a personal data breach that puts people at risk, and you must tell the affected people without delay if the risk is high. Telephone and internet providers report through a separate channel under separate rules. And if the police send you an order to take down terrorist content, you have one hour.High confidence
What's the trap?: Five things that cost people their weekend. First, Ireland's famous ban on advertising to children has never actually switched on. Second, the official copy of the law on the government's own statute website can be out of date and misleading. Third, a child in Ireland is anyone under 16 for consent purposes, not 13. Fourth, some record-keeping failures are crimes, not fines. Fifth, the regulator can only fine a public body up to 1 million euro (about 1.1 million US dollars), so it uses stop orders instead.High confidence
What's about to change?: Three things land in the next year. Ireland's new health records law is switching on in stages, and the parts that let doctors share your file and that allow sharing with countries outside Europe are still switched off. Europe's cloud switching rules make all data exit fees zero on 12 January 2027. And Ireland still has not written the European cybersecurity directive into Irish law, almost two years past the deadline.High confidence
Hardest industry wall: Finance — Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, section 106
Payments — Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, section 108I
All industries — Companies Act 2014, sections 283 and 285

BrazilChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Active

In one paragraph: Brazil does not force data to stay inside the country. Personal data can leave, but since August 2025 you normally need a contract written by the regulator, word for word, signed with whoever receives it. Sending data to the European Union needs nothing extra. The regulator is awake and has started switching features off large platforms.
The catch: Brazil is often listed as a data-localisation country. It is not one. The old rule that pushed federal government email and data onto Brazilian systems was scrapped in 2018, and today's federal cloud rules do not require Brazilian soil. The real constraints are different in shape: banks must keep the central bank able to reach their data wherever it sits, and since July 2026 digital platforms must have an actual office and a legal representative inside Brazil.
Does this apply to me?: Yes. Brazil's privacy law reaches a company with no office in Brazil, as long as it collects data in Brazil or offers goods or services to people here. There is no size or revenue threshold that lets you out. The privacy law itself does not make you appoint anyone local — but two newer rules do, and if you run a digital platform you now need a registered office and a legal representative in Brazil.High confidence
Can the data leave the country?: Yes, with paperwork. Brazil has no rule making anyone keep a copy of anything inside the country — not for banks, not for hospitals, not even for the federal government's own cloud. What it has instead is a permission slip: before personal data leaves, you need one of a short list of approved legal grounds. Industry rules add conditions on top, but none of them is a wall.High confidence
What do I have to do to send it abroad?: Pick one of five routes. The easy one is the European Union: since January 2026 Brazil treats it as safe, so nothing extra is needed. For everywhere else, the normal route is a set of standard contractual clauses that the regulator itself wrote — you copy them into your contract exactly, and you may not edit them. A deadline to retrofit older contracts already passed, on 23 August 2025.High confidence
Who enforces this — and are they actually working?: The National Data Protection Authority, and it is genuinely working. A law passed in February 2026 gave it real independence, 200 new specialist jobs and its own budget. In August 2026 it ordered Discord to switch off live video streaming in Brazil within three working days, to protect children. Banking, telecoms, insurance and securities regulators enforce their own rules in parallel and have done so for years.High confidence
How long must I keep it, and when must I delete it?: Both directions, and they pull against each other. The floor: internet access providers must keep connection records for one year, websites and apps must keep access records for six months, and tax records need five years. The ceiling: the privacy law says personal data must be deleted once you have finished doing what you collected it for. Where the two clash, the legal duty to keep wins — the law lists that as an express reason to hold on.High confidence
What happens when something goes wrong?: Count three clocks, not one. Privacy: three working days to tell the regulator AND the affected people, once you have confirmed a breach that could really hurt them. Platform content: two hours to take down intimate images shared without consent, once notified. On top of that, banks report incidents to the central bank and telecoms operators report to the telecoms regulator under their own separate timetables.High confidence
What's the trap?: Five. (1) Your European standard contract is not automatically good enough — Brazil wrote its own clauses and you must copy them exactly, unedited, and the deadline to fix old contracts passed on 23 August 2025. (2) A child in Brazil is under 12 and an adolescent is 12 to 17, but the social media rule bites at 16 — accounts for anyone up to 16 must be tied to a parent's account, and asking users to state their own age is banned. (3) Since 20 July 2026 a digital platform needs an actual registered office in Brazil, not just a lawyer on retainer. (4) The biggest fine is not in the privacy law: the internet law allows up to 10 percent of your group's Brazilian revenue. (5) The regulator can order your database blocked or your processing suspended, which usually hurts more than any cheque.High confidence
What's about to change?: One firm date: January 2027, when the regulator moves from monitoring platforms to full enforcement of the children's digital rules. Brazil's artificial intelligence bill is still only a bill — it was sitting in a committee waiting for a report as recently as June 2026, so do not plan around it. The bigger risk is not new law: it is that the regulator can add or withdraw approved destinations for data transfers by publishing a single resolution, with no consultation.High confidence
Hardest industry wall: None found.

The eight framework questions answered for each selected country
Question	IrelandChecked 18 August 2026	BrazilChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Aggressive	Yes, with paperwork Work: High Enforcement: Active
In one paragraph	Ireland follows Europe's rules, so personal data can leave the country once you have the right paperwork in place. But a handful of Irish laws force certain records to be kept physically in Ireland, and breaking those is a crime rather than a fine. Ireland's privacy regulator is one of the toughest in Europe: in 2025 it fined TikTok 530 million euro and ordered it to stop sending data to China.	Brazil does not force data to stay inside the country. Personal data can leave, but since August 2025 you normally need a contract written by the regulator, word for word, signed with whoever receives it. Sending data to the European Union needs nothing extra. The regulator is awake and has started switching features off large platforms.
The catch	The relaxed headline stops being true in four places. Trust and company service providers, and cheque-cashing firms, must keep their anti-money-laundering records at premises inside Ireland for six years, and failing to do so is a criminal offence carrying up to five years in prison. Every Irish company must keep accounting information and returns at a place in Ireland even when the books themselves sit on a foreign server. Health records and telephone and internet connection records each have their own separate rules on top.	Brazil is often listed as a data-localisation country. It is not one. The old rule that pushed federal government email and data onto Brazilian systems was scrapped in 2018, and today's federal cloud rules do not require Brazilian soil. The real constraints are different in shape: banks must keep the central bank able to reach their data wherever it sits, and since July 2026 digital platforms must have an actual office and a legal representative inside Brazil.
Does this apply to me?	Yes. Ireland's data protection law reaches a company with no office in Ireland whenever it offers goods or services to people in Europe or watches what they do online. There is no revenue or headcount threshold to duck under. A company based outside Europe normally has to name a representative inside Europe who regulators and members of the public can write to.High confidence	Yes. Brazil's privacy law reaches a company with no office in Brazil, as long as it collects data in Brazil or offers goods or services to people here. There is no size or revenue threshold that lets you out. The privacy law itself does not make you appoint anyone local — but two newer rules do, and if you run a digital platform you now need a registered office and a legal representative in Brazil.High confidence
Can the data leave the country?	In general, yes, with paperwork. Ireland does not have a general rule saying personal data must stay in the country. Sending it outside Europe is allowed once you use one of the approved legal routes. But several Irish laws quietly demand that particular records sit on Irish soil, and those override the friendly headline.High confidence	Yes, with paperwork. Brazil has no rule making anyone keep a copy of anything inside the country — not for banks, not for hospitals, not even for the federal government's own cloud. What it has instead is a permission slip: before personal data leaves, you need one of a short list of approved legal grounds. Industry rules add conditions on top, but none of them is a wall.High confidence
What do I have to do to send it abroad?	Ireland uses the European model. A destination outside Europe is off limits unless it is on the European Commission's approved list, or you put an approved safeguard in place first. The approved list is real and populated: it currently covers seventeen destinations, including the United Kingdom, Japan, South Korea, Switzerland and Brazil. The United States counts only for companies that have signed up to the European Union to United States Data Privacy Framework.High confidence	Pick one of five routes. The easy one is the European Union: since January 2026 Brazil treats it as safe, so nothing extra is needed. For everywhere else, the normal route is a set of standard contractual clauses that the regulator itself wrote — you copy them into your contract exactly, and you may not edit them. A deadline to retrofit older contracts already passed, on 23 August 2025.High confidence
Who enforces this — and are they actually working?	The Data Protection Commission, and it is very much awake. It has three commissioners in post — Des Hogan as chairperson, Dale Sunderland and Niamh Sweeney — and it published its 2025 annual report on 30 June 2026. In 2025 it finished four large inquiries and imposed fines of just over 530 million euro (about 580 million US dollars), almost all of it on TikTok, which it also ordered to stop sending European user data to China.High confidence	The National Data Protection Authority, and it is genuinely working. A law passed in February 2026 gave it real independence, 200 new specialist jobs and its own budget. In August 2026 it ordered Discord to switch off live video streaming in Brazil within three working days, to protect children. Banking, telecoms, insurance and securities regulators enforce their own rules in parallel and have done so for years.High confidence
How long must I keep it, and when must I delete it?	Both directions apply, and Ireland's floors are longer than most people expect. Anti-money-laundering customer records must be kept for at least five years. Company accounting records and returns must be kept for at least six years. Trust and company service providers and cheque-cashing firms must keep their records for six years and keep them in Ireland. Telephone and internet providers must keep subscriber details for one year.High confidence	Both directions, and they pull against each other. The floor: internet access providers must keep connection records for one year, websites and apps must keep access records for six months, and tax records need five years. The ceiling: the privacy law says personal data must be deleted once you have finished doing what you collected it for. Where the two clash, the legal duty to keep wins — the law lists that as an express reason to hold on.High confidence
What happens when something goes wrong?	Count three clocks, not one. You have 72 hours to tell the Data Protection Commission about a personal data breach that puts people at risk, and you must tell the affected people without delay if the risk is high. Telephone and internet providers report through a separate channel under separate rules. And if the police send you an order to take down terrorist content, you have one hour.High confidence	Count three clocks, not one. Privacy: three working days to tell the regulator AND the affected people, once you have confirmed a breach that could really hurt them. Platform content: two hours to take down intimate images shared without consent, once notified. On top of that, banks report incidents to the central bank and telecoms operators report to the telecoms regulator under their own separate timetables.High confidence
What's the trap?	Five things that cost people their weekend. First, Ireland's famous ban on advertising to children has never actually switched on. Second, the official copy of the law on the government's own statute website can be out of date and misleading. Third, a child in Ireland is anyone under 16 for consent purposes, not 13. Fourth, some record-keeping failures are crimes, not fines. Fifth, the regulator can only fine a public body up to 1 million euro (about 1.1 million US dollars), so it uses stop orders instead.High confidence	Five. (1) Your European standard contract is not automatically good enough — Brazil wrote its own clauses and you must copy them exactly, unedited, and the deadline to fix old contracts passed on 23 August 2025. (2) A child in Brazil is under 12 and an adolescent is 12 to 17, but the social media rule bites at 16 — accounts for anyone up to 16 must be tied to a parent's account, and asking users to state their own age is banned. (3) Since 20 July 2026 a digital platform needs an actual registered office in Brazil, not just a lawyer on retainer. (4) The biggest fine is not in the privacy law: the internet law allows up to 10 percent of your group's Brazilian revenue. (5) The regulator can order your database blocked or your processing suspended, which usually hurts more than any cheque.High confidence
What's about to change?	Three things land in the next year. Ireland's new health records law is switching on in stages, and the parts that let doctors share your file and that allow sharing with countries outside Europe are still switched off. Europe's cloud switching rules make all data exit fees zero on 12 January 2027. And Ireland still has not written the European cybersecurity directive into Irish law, almost two years past the deadline.High confidence	One firm date: January 2027, when the regulator moves from monitoring platforms to full enforcement of the children's digital rules. Brazil's artificial intelligence bill is still only a bill — it was sitting in a committee waiting for a report as recently as June 2026, so do not plan around it. The bigger risk is not new law: it is that the regulator can add or withdraw approved destinations for data transfers by publishing a single resolution, with no consultation.High confidence
Hardest industry wall	Finance — Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, section 106 Payments — Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, section 108I All industries — Companies Act 2014, sections 283 and 285	None found.