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
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