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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

United StatesChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
The catch: The open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
Does this apply to me?: Yes. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from Europe.High confidence
Can the data leave the country?: It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.High confidence
What do I have to do to send it abroad?: For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.High confidence
Who enforces this — and are they actually working?: Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.High confidence
How long must I keep it, and when must I delete it?: There is a strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.High confidence
What happens when something goes wrong?: Count the clocks — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.High confidence
What's the trap?: Five that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.High confidence
What's about to change?: Four things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.High confidence
Hardest industry wall: Government — Criminal Justice Information Services (CJIS) Security Policy
Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies
Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services
Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector

The eight framework questions answered for each selected country
Question	IsraelChecked 18 August 2026	United StatesChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Active	Depends on your industry Work: High Enforcement: 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.	In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
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 open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
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. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from Europe.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	It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.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	For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.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	Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.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 a strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.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	Count the clocks — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.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	Five that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.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	Four things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.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	Government — Criminal Justice Information Services (CJIS) Security Policy Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector