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

Countries

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

IndiaChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Waking up

In one paragraph: India's general privacy law is unusually relaxed about sending data abroad — it bans transfers only to countries on a government blacklist, and that blacklist is currently empty. But specific industries have hard walls: payments data, insurance records and telecom network data must stay inside India. The main law is passed but most of it only becomes enforceable in May 2027, and the regulator has no members yet.
The catch: The permissive headline is true only until you touch payments, insurance, telecom infrastructure, government cloud, public-health records or detailed mapping data. In those six areas India is one of the strictest jurisdictions in the world.
Does this apply to me?: Yes, it reaches you even with no office in India. The law applies to any organisation anywhere in the world that processes Indians' data in connection with offering goods or services to people in India. There is no size or revenue threshold to fall below.High confidence
Can the data leave the country?: In general, yes — freely. India's approach is a blacklist: the government may name countries you cannot send data to, and as of today it has named none. Six industries are the exception and are covered below.High confidence
What do I have to do to send it abroad?: Nothing to sign, no government approval, no standard contract. Unlike Europe, India requires no paperwork to send personal data abroad under the general law — the only question is whether the destination is on the blacklist, and nothing is. Sector rules override this completely.High confidence
Who enforces this — and are they actually working?: On paper, the Data Protection Board of India. In practice, nobody yet — the Board legally exists but as of August 2026 has no chairperson and no members. The government advertised the five posts in May 2026 and re-advertised in June, and they were still vacant in August. Sector regulators, by contrast, are fully active: the central bank, the insurance and securities regulators, the telecom department and the national cyber agency all enforce today.High confidence
How long must I keep it, and when must I delete it?: There is both a floor and a ceiling. From May 2027 every organisation must keep processing logs for at least one year. Tax records run six years, company books eight, and security logs 180 days. In the other direction, large consumer platforms must delete a user's data three years after they last engaged — with 48 hours' warning to the user first.High confidence
What happens when something goes wrong?: Two clocks, and this trips up almost everyone. You have SIX HOURS to report a cyber incident to India's national cyber agency — one of the shortest deadlines in the world. Separately, from May 2027, you must tell the privacy regulator and affected individuals without delay, then file a detailed report within 72 hours.High confidence
What's the trap?: Four things that catch people out. (1) A child is anyone under 18 — there is no lower age of digital consent as there is in Europe, and targeted advertising to under-18s is banned outright. (2) A consent manager must be an Indian company with about $2.3m of net worth, so a foreign entity cannot be one. (3) If designated a 'significant' organisation you must have a data protection officer physically based in India who answers to the board. (4) The general law expressly preserves stricter sector rules, so its liberal transfer regime gives you nothing if you touch payments, insurance or telecom.High confidence
What's about to change?: Three dates matter. 13 November 2026: consent managers must register. 13 May 2027: the whole law becomes enforceable, and the government has publicly refused to extend it or exempt startups. At some point before then, the Board should get its members — at which point enforcement switches on.High confidence
Hardest industry wall: Payments — Storage of Payment System Data
Telecoms — Telecommunications (Authorisation) Rules, 2026
Insurance — IRDAI (Maintenance of Information by Regulated Entities and Sharing of Information by the Authority) Regulations, 2025
Securities — Cybersecurity and Cyber Resilience Framework, control PR.DS.S2
All industries — Directions under section 70B(6) of the Information Technology Act, 2000

The eight framework questions answered for each selected country
Question	IsraelChecked 18 August 2026	IndiaChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Active	Depends on your industry Work: High Enforcement: Waking up
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.	India's general privacy law is unusually relaxed about sending data abroad — it bans transfers only to countries on a government blacklist, and that blacklist is currently empty. But specific industries have hard walls: payments data, insurance records and telecom network data must stay inside India. The main law is passed but most of it only becomes enforceable in May 2027, and the regulator has no members yet.
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.	The permissive headline is true only until you touch payments, insurance, telecom infrastructure, government cloud, public-health records or detailed mapping data. In those six areas India is one of the strictest jurisdictions in the world.
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	Yes, it reaches you even with no office in India. The law applies to any organisation anywhere in the world that processes Indians' data in connection with offering goods or services to people in India. There is no size or revenue threshold to fall below.High 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	In general, yes — freely. India's approach is a blacklist: the government may name countries you cannot send data to, and as of today it has named none. Six industries are the exception and are covered below.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	Nothing to sign, no government approval, no standard contract. Unlike Europe, India requires no paperwork to send personal data abroad under the general law — the only question is whether the destination is on the blacklist, and nothing is. Sector rules override this completely.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	On paper, the Data Protection Board of India. In practice, nobody yet — the Board legally exists but as of August 2026 has no chairperson and no members. The government advertised the five posts in May 2026 and re-advertised in June, and they were still vacant in August. Sector regulators, by contrast, are fully active: the central bank, the insurance and securities regulators, the telecom department and the national cyber agency all enforce today.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	There is both a floor and a ceiling. From May 2027 every organisation must keep processing logs for at least one year. Tax records run six years, company books eight, and security logs 180 days. In the other direction, large consumer platforms must delete a user's data three years after they last engaged — with 48 hours' warning to the user first.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	Two clocks, and this trips up almost everyone. You have SIX HOURS to report a cyber incident to India's national cyber agency — one of the shortest deadlines in the world. Separately, from May 2027, you must tell the privacy regulator and affected individuals without delay, then file a detailed report within 72 hours.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	Four things that catch people out. (1) A child is anyone under 18 — there is no lower age of digital consent as there is in Europe, and targeted advertising to under-18s is banned outright. (2) A consent manager must be an Indian company with about $2.3m of net worth, so a foreign entity cannot be one. (3) If designated a 'significant' organisation you must have a data protection officer physically based in India who answers to the board. (4) The general law expressly preserves stricter sector rules, so its liberal transfer regime gives you nothing if you touch payments, insurance or telecom.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	Three dates matter. 13 November 2026: consent managers must register. 13 May 2027: the whole law becomes enforceable, and the government has publicly refused to extend it or exempt startups. At some point before then, the Board should get its members — at which point enforcement switches on.High 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	Payments — Storage of Payment System Data Telecoms — Telecommunications (Authorisation) Rules, 2026 Insurance — IRDAI (Maintenance of Information by Regulated Entities and Sharing of Information by the Authority) Regulations, 2025 Securities — Cybersecurity and Cyber Resilience Framework, control PR.DS.S2 All industries — Directions under section 70B(6) of the Information Technology Act, 2000