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Two or three countries, side by side, one row per question. Pick up to 3.
CambodiaChecked 18 August 2026
Depends on your industryWork: LowEnforcement: Dormant
- In one paragraph
- Cambodia has no general privacy law. A bill exists and went to a public review meeting in August 2026, but it is not law and there is no privacy regulator to complain to. For most businesses data can leave the country freely, with no paperwork. Banks and other lenders are the big exception: their main data centre must sit inside Cambodia.
- The catch
- The relaxed headline stops at the door of the financial sector. Any bank or lender supervised by Cambodia's central bank must keep at least one main data centre inside the country, and must get the central bank's permission in advance before customer personal data is moved to or hosted on servers abroad. Telecoms are also watched closely by an active regulator, and a suspended 2021 order that would push all internet traffic through a single government-controlled gateway can be switched back on at any time.
- Does this apply to me?
- There is no general data protection law in Cambodia, so there is nothing for a foreign company to be caught by. No size threshold, no revenue threshold, no registration, and no requirement to appoint someone in Cambodia to answer for your data. That changes the moment you need a local licence: banks, lenders and telecoms operators are licensed here and their licence conditions do reach their overseas systems. A draft privacy law was put to a validation workshop on 5 August 2026 and will proceed through the formal law-making process, so this answer has a shelf life.High confidence
- Can the data leave the country?
- In general, yes, and with nothing to sign. Cambodia has no rule that stops ordinary personal data leaving the country. Finance is the one hard wall we could verify: a bank or lender supervised by the central bank must have at least one main data centre in Cambodia, may only use a foreign data centre as a backup, and needs the central bank's approval before customer personal data is hosted abroad. Telecoms is the sector to watch, because a 2021 order that would route all internet traffic through a single national gateway was never switched on but was never cancelled either.Medium confidence
- What do I have to do to send it abroad?
- For most organisations, nothing at all. There is no approved-countries list, no banned-countries list, no standard contract to sign and no government form to file. The lists are not just empty, they do not exist, because there is no law that creates them. In finance the model is completely different: each move of customer personal data out of Cambodia needs its own approval from the central bank, decided case by case, and there is no published application process or timetable.Medium confidence
- Who enforces this — and are they actually working?
- For privacy, nobody. Cambodia has no data protection authority. The Ministry of Post and Telecommunications is writing the law and, in November 2025, ran a training workshop with Singapore's privacy regulator on how to build such an authority, which tells you plainly that one does not yet exist. Sector regulators are a different story and are genuinely working: the central bank supervises financial firms against its 2026 technology guidelines, and the telecoms regulator publicly named an operator in June 2026 for selling SIM cards without properly checking customers' identity documents.High confidence
- How long must I keep it, and when must I delete it?
- There is a floor and almost no ceiling. Tax and accounting law forces businesses to keep books and supporting documents for years, and financial firms must keep system logs and agree retention periods with their cloud providers. In the other direction there is no general rule telling anyone to delete personal data, because there is no privacy law. The only deletion duty we could verify applies to banks and lenders, who must keep customer personal data only as long as it is needed.Medium confidence
- What happens when something goes wrong?
- There is no breach reporting clock in Cambodia. No law requires you to tell a regulator or the affected people when personal data leaks, and there is no national cyber incident hotline with a deadline in hours. The nearest thing is in banking: the central bank tells supervised firms to report incidents as it requires, either on a regular cycle or one-off, with no fixed number of hours. Two draft laws would change this, so treat today's silence as temporary.Medium confidence
- What's the trap?
- Five things that are not in the summary. First, the e-commerce law reportedly bans encryption that would stop evidence being used in a criminal case, which cuts across normal end-to-end encryption promises. Second, a cloud-only bank cannot operate here: the main data centre must physically be in Cambodia. Third, moving customer banking data abroad needs the central bank's permission in advance, and there is no published process or timetable, so it must be planned months ahead. Fourth, telecoms operators must check identity documents before activating a SIM card, and the regulator names offenders in public. Fifth, no privacy law does not mean no risk, because your foreign customers will impose their own rules by contract.Medium confidence
- What's about to change?
- Four drafts are moving and none of them is law yet. The Personal Data Protection Law reached a validation workshop on 5 August 2026 and now heads into the formal law-making process. The Cybersecurity Law was still being argued over with the Ministry of Justice in July 2026. A Data Governance Policy for 2026 to 2035 was in consultation in March 2026 and is expected to cover where data may be stored and how it may cross borders. A Digital Government Law went to consultation in July 2025. No commencement date has been announced for any of them.High confidence
- Hardest industry wall
- Finance — Technology and Cyber Risk Management Guidelines (TCRMG)
CyprusChecked 18 August 2026
Depends on your industryWork: HighEnforcement: Active
- In one paragraph
- For most businesses Cyprus behaves like a normal European country: data can leave, provided you use one of the standard European transfer tools. Two things make it stricter than its neighbours. If you move sensitive data such as health records out of Europe, you must tell the privacy regulator first. And breaking the privacy law in Cyprus is a crime, not just a fine.
- The catch
- The relaxed European headline stops being true in three places. Online betting operators must run a backup server physically inside Cyprus that mirrors their main one. Anyone sending sensitive data out of Europe must notify the regulator before the data moves, and she can order the transfer stopped. And insurers may not process genetic or fingerprint-type data for health or life cover at all. Outside those, Cyprus imposes no storage-location rule of its own.
- Does this apply to me?
- Yes. If you have no office anywhere in Europe but you sell to people in Cyprus, or you watch what they do online, the European privacy rules reach you and the Cypriot regulator can act. There is no minimum size or turnover that lets you escape. A company with no European base must name a written representative inside Europe, and the Cypriot law adds its own duties on top for anyone processing data here.High confidence
- Can the data leave the country?
- In general yes, with paperwork. Ordinary personal data leaves Cyprus on the same European terms as anywhere else in the bloc. But three Cypriot rules override that. Sensitive data going outside Europe must be notified to the regulator before it moves. Online betting operators must keep a mirror copy on a server inside Cyprus. And insurers cannot process genetic or fingerprint data for health or life cover at all.High confidence
- What do I have to do to send it abroad?
- The model is an approved-destination list. Data may go to a country the European Commission has approved, or you sign the European standard contract, or you use approved group-wide rules. Cyprus adds one step of its own: if the data is sensitive, tell the regulator before it goes, and if you are relying on a narrow exception rather than a contract, do a written risk assessment and consult her first.High confidence
- Who enforces this — and are they actually working?
- The Commissioner for Personal Data Protection, and she is genuinely working. In 2024 her office took 531 complaints and 94 breach reports, issued 88 decisions, and fined in 21 of them, totalling about 133,900 euros (roughly $146,000). The biggest single penalty, 46,500 euros, went to the state health services organisation. The current Commissioner is Maria Christofidou. A separate Digital Security Authority handles cyber incidents and is also active.High confidence
- How long must I keep it, and when must I delete it?
- There is no single national rule. The European ceiling applies: delete personal data once you no longer need it for the purpose you collected it for. The floors come from sector law. Betting operators must keep betting slips and related documents for five years, and may not destroy them afterwards without the regulator's permission. Where a floor and the ceiling collide, the specific legal duty to keep wins, but only for the data that duty actually covers.Medium confidence
- What happens when something goes wrong?
- Count three clocks and start with the shortest. If you run an essential or important service, Cyprus gives you SIX HOURS to send a first warning to the Digital Security Authority — one of the tightest deadlines in Europe, and far shorter than the 24 hours the European directive asked for. A full report follows within 72 hours and a final one within a month. Separately, a personal data breach goes to the privacy regulator within 72 hours, and to affected people if the risk to them is high.High confidence
- What's the trap?
- Five things that are not in the summary. (1) Breaking the privacy law in Cyprus is a crime — up to three years in prison, or five where national security is touched — and the law puts the blame on the company's most senior executive personally. (2) A child is anyone under 14 here, not 16 as in some neighbours. (3) Insurers may not use genetic or fingerprint-type data for health or life cover at all. (4) Sensitive data leaving Europe must be notified to the regulator first. (5) The cyber warning deadline is six hours, not 24.High confidence
- What's about to change?
- One hard European date matters most: from 12 January 2027 cloud providers must let customers move away with no exit or switching fees. Cyprus is also still building out its newest laws — the digital services law passed in 2025 and the artificial intelligence rules are being bedded in by the same privacy regulator, who now has three jobs instead of one. Watch three switches the government can flip with no warning.Medium confidence
- Hardest industry wall
- Insurance — Νόμος 125(Ι)/2018, άρθρο 9 — Επεξεργασία γενετικών και βιομετρικών δεδομένων
- Online gaming — Ο περί Στοιχημάτων Νόμος του 2019