Compare countries
Two or three countries, side by side, one row per question. Pick up to 3.
South KoreaChecked 18 August 2026
Depends on your industryWork: HighEnforcement: Aggressive
- In one paragraph
- South Korea's privacy law bans sending personal data abroad unless you have one of five grounds. The usual one is a separate consent, ticked apart from every other consent. Since September 2025 the 30 European countries need no extra paperwork. But banking, health records, government cloud and detailed maps have hard walls no consent can unlock, and the regulator fines foreign companies often.
- The catch
- The 'get consent and send it' headline stops being true the moment you touch six areas: bank and payment systems, financial customers' national ID numbers, hospital records, government cloud, detailed mapping data, and personal location services. In those areas the data or the machine holding it must physically sit in South Korea, and in the government cloud case so must the people who run it.
- Does this apply to me?
- Yes. The regulator fines companies with no Korean office. In July 2026 it fined TikTok's Singapore company and two Apple companies based in Ireland and Singapore for collecting Korean users' data and sending it abroad without a proper legal basis. If your worldwide revenue was 1 trillion won (about $720 million) or more last year, or you held data on an average of 1 million or more people in Korea per day over the last three months of last year, you must appoint a representative in Korea. Since April 2026, if you already own or control a Korean company, that Korean company has to be the representative.High confidence
- Can the data leave the country?
- In general yes, but only if you have one of five grounds, and the usual one is a separate consent that the person ticks apart from every other consent. Since September 2025 you can also send data to the 27 European Union countries plus Norway, Iceland and Liechtenstein with no extra step at all, because the regulator has formally accepted their protection as equal to Korea's. That is the only such list, and no other country is on it. Six industries override all of this and are covered below.High confidence
- What do I have to do to send it abroad?
- Korea does not police the destination. It polices your paperwork. There is no banned-country list and no approval application to file: you pick one of the five grounds, and for most companies that means asking each person for a separate transfer consent that lists what goes, where, to whom, for how long and how to refuse. The one destination list that exists is a positive one, and it holds exactly 30 countries: the European Union plus Norway, Iceland and Liechtenstein. Send data anywhere else and you also have to keep security measures, a complaints route and a dispute process in place, and write the transfer into your contract with the recipient.High confidence
- Who enforces this — and are they actually working?
- The Personal Information Protection Commission, chaired by Song Kyoung-hee, and it is one of the busiest privacy regulators in the world right now. In July 2026 alone it fined the telecoms company KT about 54 billion won (roughly $39 million) over a data breach, fined TikTok about 10.3 billion won (roughly $7.4 million) and Apple about 252 million won (roughly $180,000). It referred KT to prosecutors for obstructing the investigation and asked police to investigate LG U+ for destroying a server before the inquiry started. Finance is separately policed by the Financial Services Commission and the Financial Supervisory Service; health by the health ministry; maps by an inter-agency committee that includes the intelligence service.High confidence
- How long must I keep it, and when must I delete it?
- Two forces pull in opposite directions. The ceiling: you must destroy personal data without delay once you no longer need it, and destroy it so it cannot be recovered. The floor: other laws make you keep things. An online seller must keep advertising records for 6 months, complaint and dispute records for 3 years, and contract, cancellation, payment and delivery records for 5 years. Almost everyone must keep system access logs for at least 1 year, and 2 years if the system holds data on 50,000 or more people, holds national ID numbers or sensitive data, or belongs to a licensed telecoms carrier. When the two clash, the keeping rule wins, but you must store that data separately from everything else.High confidence
- What happens when something goes wrong?
- Count two clocks, and in telecoms and finance a third. Under the privacy law you have 72 hours to tell the affected people, and a separate 72 hours to report to the Commission or to the Korea Internet and Security Agency. The reporting clock starts if 1,000 or more people are affected, or if any sensitive data or national ID numbers leaked, or if the cause was someone breaking in from outside. Separately, an internet service provider must report a cyber incident to the science ministry or the same agency immediately. A hospital must also tell the health ministry about a medical-records incident.High confidence
- What's the trap?
- Five things that will cost you a weekend. One: the children's age line is 14, not 13 or 16, and processing an under-14's data without a parent's consent is a crime punishable by up to five years in prison, not just a fine. Two: hiding or destroying material during a regulator's inspection is itself a crime, and the regulator used it in July 2026. Three: stripping names out of a dataset does not free it. Four: a bank's Korean customers' national ID numbers may not leave the country at all, and any offshore processing of customers' financial transaction data needs a report to the supervisor 30 business days before work starts. Five: if you want to run a personal location service you must be a corporation and be registered, so you cannot serve Korea from abroad with no entity.High confidence
- What's about to change?
- The privacy regulator started rewriting the rulebook for artificial intelligence. It set up a reform task force on 30 July 2026, ran a public suggestion window from 6 to 31 August 2026, and plans to publish the direction of reform before the end of 2026. Consent-based rules and the block on sending pseudonymised data abroad for research are both explicitly on the table. Separately, Apple's request to export detailed Korean map data has been pending since its deadline was extended in December 2025, and Google's equivalent request was granted in February 2026 on strict conditions, so the mapping picture can move again at any time.High confidence
- Hardest industry wall
- Banking — 전자금융감독규정 (Regulation on Supervision of Electronic Financial Transactions)
- Finance — 금융회사의 정보처리 업무 위탁에 관한 규정 (Regulation on Outsourcing of Data Processing Business by Financial Companies)
- Health and social care — 전자의무기록의 관리·보존에 필요한 시설과 장비에 관한 기준 (Standards for the Facilities and Equipment Required to Manage and Preserve Electronic Medical Records)
- Government — 클라우드컴퓨팅서비스 보안인증에 관한 고시 (Notice on Security Certification of Cloud Computing Services)
- Mapping and location — 공간정보의 구축 및 관리 등에 관한 법률 (Act on the Establishment and Management of Spatial Data)
CanadaChecked 18 August 2026
Depends on your industryWork: HighEnforcement: Active
- In one paragraph
- Canada lets data leave the country. There is no approved-country list and no banned-country list. You stay responsible for the data wherever it goes, and you must tell people it may be handled abroad. The catch is that Canada is really ten jurisdictions at once, and several of them add hard storage rules on top of the national one.
- The catch
- The relaxed national answer stops being true the moment you touch four things: personal information about people in Quebec, a Nova Scotia public body or its suppliers, federal government data rated Protected B or higher, or a federally regulated bank. Add to that a brand-new cyber security law that says records about critical systems in banking, telecoms, energy and transport must be kept in Canada. In those places Canada is genuinely restrictive.
- Does this apply to me?
- Yes. Canada's national privacy law reaches a foreign company with no office here if it handles personal information about people in Canada as part of doing business. There is no revenue or headcount threshold that lets you out. You do not normally need a local representative, but payment companies are an exception: a payment firm based abroad that aims its service at people in Canada must register with the central bank and name an agent inside Canada to receive official notices.High confidence
- Can the data leave the country?
- In general, yes, and with no government permission. Canada's national law does not restrict where personal data is stored or processed. But the headline is wrong for at least six groups. Quebec makes you do a written risk assessment first — and that applies even to sending data to Ontario. Nova Scotia public bodies and their suppliers must keep the data in Canada. Federal government data rated Protected B or higher must sit in Canada. Banks must keep a full copy of their records on servers in Canada. And under the new cyber security law, records about critical systems must be kept in Canada.High confidence
- What do I have to do to send it abroad?
- At the national level there is no list at all — no approved countries, no banned countries, no government form to file. What you must do instead is stay accountable: put a contract or similar protection in place with whoever handles the data for you, and tell people plainly that their information may be processed in another country and could be seen by foreign courts, police or security agencies. Quebec is different and stricter: there you must complete a written privacy risk assessment before the data moves, and sign a written agreement.High confidence
- Who enforces this — and are they actually working?
- Canada has many regulators and they are all real, staffed and issuing decisions. The national one, the Privacy Commissioner of Canada, published findings against OpenAI, X, Bell and WestJet in the first half of 2026 alone. But it cannot fine anyone — it makes findings and recommendations, and a case has to go to the Federal Court for money. Quebec's regulator can fine, and has blocked a national grocery chain from switching on a face-recognition system. Banking, payments and cyber security each have their own separate supervisor.High confidence
- How long must I keep it, and when must I delete it?
- The floor and the ceiling pull in opposite directions. Tax law says keep your business records for six years after the tax year they relate to, and keep them at a place of business in Canada unless the tax authority agrees to somewhere else. Privacy law says the opposite: delete personal information once the reason you collected it has gone. Where the two clash, the duty to keep wins — but only for the specific records the law names, and only for as long as it names.High confidence
- What happens when something goes wrong?
- Count at least four clocks and they do not agree. The national privacy law gives no fixed number of hours — you report 'as soon as feasible', which in practice means days, not weeks. Payment firms get 48 hours to tell the central bank about a serious incident. Critical infrastructure operators will get no more than 72 hours to tell the national cyber agency, then must tell their own regulator immediately after. Health and provincial rules add more. The overlap is where people get caught: one incident, several reports, several deadlines.High confidence
- What's the trap?
- Five things that are not in any summary. Quebec's cross-border rule catches you sending data to Ontario, not just abroad. Quebec also makes you tell its regulator 60 days before you switch on any face or fingerprint system, and it has already blocked a big grocery chain from doing so. British Columbia repealed its keep-it-in-Canada rule in 2021, so trackers that still show it are wrong. Nova Scotia's Canada-only rule reaches private suppliers, with fines up to half a million dollars. And your tax records have to sit at a place of business in Canada.High confidence
- What's about to change?
- One big bill and one big law already passed. The bill is Canada's third attempt to replace its 25-year-old privacy law: it would force a written risk assessment before any personal data goes outside Canada, give people a right to have data deleted, treat everyone under 18 as sensitive, and set up a new commissioner. It was only introduced in June 2026 and is not law — do not plan around it as if it were. The law already passed is the cyber security act, which switches on in stages over the coming year.High confidence
- Hardest industry wall
- Government — Personal Information International Disclosure Protection Act
- Government — Direction for Electronic Data Residency (ITPIN 2017-02), with the Policy on Service and Digital
- Banking — Guideline B-10 Third-Party Risk Management, read with Bank Act section 245 and the equivalent provisions of the Insurance Companies Act and Trust and Loan Companies Act
- All industries — Critical Cyber Systems Protection Act, enacted by the Cyber Security Act (Bill C-8)