Compare countries
Two or three countries, side by side, one row per question. Pick up to 3.
IsraelChecked 18 August 2026
Yes, with paperworkWork: HighEnforcement: Active
- In one paragraph
- Israeli data can go abroad, but never by default. Either the destination country protects data as well as Israel does, or you fit one of eight listed exceptions — usually a contract in which the receiver promises to follow Israeli rules. A big reform started on 14 August 2025 and the regulator now issues real fines. No industry bans exports outright, but several add heavy conditions.
- The catch
- The general answer is 'yes, with paperwork'. It stops being true in four places. Banks may not put sensitive customer data on a cloud outside Israel unless they have checked the provider meets European-level protection. Insurers and pension bodies must report every offshore outsourcing arrangement to their regulator each year. Identifiable patient data used for research must generally stay inside the hospital or health fund that holds it, not merely inside Israel. And central government has moved its own cloud into Israeli data-centre regions on purpose, so selling cloud to the state effectively requires an Israeli region.
- Does this apply to me?
- Yes, it can reach a foreign company with no office in Israel — but the law never says so in words. Israeli privacy law simply applies to anyone who collects, uses or processes personal data, with no size or revenue threshold to fall under. There is no general requirement to appoint a local representative. Some organisations must appoint a privacy officer, and that person is allowed to be an outside contractor rather than a staff member.Medium confidence
- Can the data leave the country?
- Yes, with paperwork — and you must be able to name the route you are using. The default rule is that data may only go to a country whose law protects it at least as well as Israeli law does. If the destination fails that test, you have to fit one of eight listed exceptions, and whichever route you take you also need a written promise from the receiver. No Israeli industry has a flat 'the data stays here' rule, but four sectors bolt extra conditions on top.High confidence
- What do I have to do to send it abroad?
- The model is closest to an allowlist: you may not send data out unless the destination qualifies, and the qualifying list is already populated. It counts if the country signed the Council of Europe data protection convention, or if it receives data from European Union countries on the same terms — so Europe's approved-country list does much of the work. If your destination does not qualify, the usual fallback is a contract in which the receiver promises to meet Israeli standards. Either way you also need a separate written promise from the receiver that it will protect the data and pass it to nobody else.High confidence
- Who enforces this — and are they actually working?
- The Privacy Protection Authority, part of the Ministry of Justice, and it is fully operational. It has a serving commissioner, an administrative enforcement department, and it publishes its decisions with names and amounts. In 2026 it fined a national health fund about 256,000 shekels (roughly $72,000) for taking two months to report a security incident, and a small leisure company about 12,000 shekels (roughly $3,400) for a defective privacy notice. Industry regulators — the Bank of Israel, the insurance regulator and the Ministry of Health — enforce their own rules separately.High confidence
- How long must I keep it, and when must I delete it?
- There is a clear floor and a clear ceiling, and they sit close together. The floor: security and access-monitoring records must be kept for at least 24 months, and organisations with medium or high security databases must keep a restorable backup of them. The ceiling: if a database contains anything that came from Europe, you must run a mechanism that finds data you no longer need and delete it, and you must delete data on request. Where another law says you must keep something, that wins over the duty to delete.High confidence
- What happens when something goes wrong?
- There is one main clock and it has no hours attached to it: a severe security incident must be reported to the Privacy Protection Authority immediately, along with what you did about it. 'Immediately' is taken literally — a health fund was fined for a two-month delay. Telling the affected people is not automatic; the Authority decides, after consulting the national cyber agency, and can order you to notify them. Israel has no general law forcing every company to report cyber incidents to the state, so your second clock, if you have one, comes from your industry regulator.High confidence
- What's the trap?
- Five things that are not in the summary. One: a single record that arrived from Europe drags the whole database into the stricter European rules — since 1 January 2025 those rules apply to any other data sitting in the same database. Two: 'immediately' really means immediately, and there is no safe 72-hour habit to fall back on. Three: fines are calculated per person, not as a flat cap, so a large database turns a small breach into a very large bill. Four: privacy breaches are criminal offences, not just regulatory ones, with prison terms attached. Five: 'data security officer' and 'data protection officer' are two different Israeli roles with different triggers, and having one does not satisfy the other.High confidence
- What's about to change?
- The big change already happened on 14 August 2025. What is landing now is the detail underneath it. In April 2026 the regulator finalised its binding rules on the contract you must sign before sending data abroad, and separate regulations came into force giving a short grace period — a warning instead of a fine — for brand-new obligations. A guideline applying privacy law to artificial intelligence, including a requirement of consent before scraping the web to train models, is also in play. Watch three switches the government can flip without warning.Medium confidence
- Hardest industry wall
- Health and social care — חוזרי מנכ"ל משרד הבריאות 1/2018 ו-2/2018 - שימושים משניים במידע בריאות
- Government — פרויקט נימבוס - מדיניות הענן הממשלתית
ArmeniaChecked 18 August 2026
Yes, with paperworkWork: MediumEnforcement: Dormant
- In one paragraph
- Armenia lets personal data leave, but only to a country on an official approved list of 53 states, or with case-by-case permission from the privacy regulator. That regulator has had no boss since February 2026 and the largest fine it can impose is about 1,300 US dollars. The real constraints are elsewhere: government data sent to a foreign cloud must keep a backup copy inside Armenia, and banking and medical secrecy sit outside the privacy law entirely.
- The catch
- The approved-country list is worthless in three places. Government bodies must keep an in-country backup of anything they put in a cloud abroad. Bank, notarial, lawyer and insurance secrets are carved out of the privacy law and are governed by their own secrecy statutes, which list exhaustively who may see the data and do not mention foreign cloud providers. And leaking medical secrets is a crime that can put a named individual in prison, not just a fine on the company.
- Does this apply to me?
- Probably not, if you have nothing in Armenia. The privacy law describes who it covers by naming Armenian public bodies, companies and individuals who process personal data. It contains no clause saying it follows Armenians' data abroad, and no rule requiring a foreign company to appoint someone inside Armenia. There is no size or revenue threshold either, so a one-person Armenian business is caught exactly like a bank.Medium confidence
- Can the data leave the country?
- Yes, with paperwork. Armenia runs an approved-country list: if the destination is on it, you can send data with no permission from anyone. The list is real and populated — 53 countries, including all of the European Union, the United Kingdom, Canada, Japan, South Korea, Israel, Georgia and Russia. Sending data anywhere else needs written permission from the privacy regulator first, and that regulator currently has nobody in the chair. Three sectors override this entirely: government, banking-type secrets, and health.High confidence
- What do I have to do to send it abroad?
- The model is an approved list, and the list is full. Fifty-three countries were approved on 8 July 2024 and that decision has never been changed. If your destination is on it you need nothing — no standard contract, no filing, no fee. If it is not on it, you must write to the regulator before you send anything, attach the contract you plan to sign, and wait up to 30 days for a yes or a no.High confidence
- Who enforces this — and are they actually working?
- On paper, the Personal Data Protection Agency inside the Ministry of Justice. In practice, nobody right now: its head resigned with effect from 24 February 2026 and no replacement appointment has been published. In more than eleven years the agency has published exactly one general decision — the approved-country list. Two other regulators are genuinely working: the Central Bank supervises banks, payment firms, insurers and securities, and a brand-new Information Systems Regulatory Commission was appointed in March and April 2026 to police cybersecurity and state computer systems.Medium confidence
- How long must I keep it, and when must I delete it?
- The floor is five years for anything that proves your tax position. The ceiling is not a number — it is a principle: you must destroy or block personal data as soon as you no longer need it for the purpose you collected it for. Two hard clocks sit inside that principle. If someone withdraws consent you have ten working days to destroy their data, then three more working days to tell them you did. If you spot unlawful processing you have three working days to fix it or destroy the data.High confidence
- What happens when something goes wrong?
- Count three clocks. Under the privacy law, if data leaks out of your electronic systems you must immediately publish a public announcement about it and at the same time tell the Armenian police and the privacy regulator — there is no grace period and no threshold. If you run a system in a sector the state calls vital, you have 24 hours to tell the cybersecurity regulator, 72 hours to send an update, two days to warn the people affected, and one month to file a final report. Both sets of duties can bite at once.High confidence
- What's the trap?
- Five things that will ruin your week. One: a data leak must be announced publicly and reported to the police, not just to the regulator. Two: encryption is legally compulsory, not a best practice, and failing to use it is its own separate fine. Three: before you process biometric or sensitive data you must notify the regulator in advance and wait to be entered in its register. Four: to process a dead person's data you need the consent of all of their legal heirs. Five: a child is anyone under 16 here, not 13 and not 18.High confidence
- What's about to change?
- Armenia rewired its digital rulebook in December 2025 and the deadlines land through 2026, 2027 and 2028. Rules for cyber incidents and for state computer systems are already live. Detailed technical rules are due by January 2027, internal cybersecurity policies and risk assessments by July 2027, and security certificates for critical systems by January 2028. The change most likely to catch someone out is not a new law at all: the approved-country list can be rewritten by one official's signature.High confidence
- Hardest industry wall
- Government — «Ամպայինն առաջինը» քաղաքականության մշակման և ներդրման մասին ՀՀ կառավարության որոշում