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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)

UkraineChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Ukraine still runs its 2010 privacy law, not a European-style one. Personal data may leave the country only to a country the law treats as safe — that means Europe and the 50-odd countries that signed a Council of Europe data treaty. The United States is not on that list. Fines are tiny, but the human rights Commissioner really does inspect, and misusing data can be a crime.
The catch: The general picture changes completely once government is involved. If a Ukrainian state body is the organisation deciding how personal data is used, only a Ukrainian state-owned or municipal company may process that data for it — a private or foreign supplier cannot. State systems, defence data and critical infrastructure also carry hard location rules, and several of the current permissions exist only because the country is under martial law.
Does this apply to me?: Probably not, if you have nothing in Ukraine. The 2010 law simply says it covers the processing of personal data by automated means or in structured paper files. It contains no clause reaching foreign companies that only sell into Ukraine from abroad, and it does not make you appoint a local representative. There is no size or revenue threshold either — a corner shop and a bank are treated the same.Medium confidence
Can the data leave the country?: Yes, but only to countries Ukraine already treats as safe. Those are the European Economic Area countries plus every country that has signed the Council of Europe's data protection treaty — roughly 55 states. The United States has signed neither, so routine transfers to American servers do not fit the safe-country route and need one of the narrow exceptions instead. Whole sectors then override this: government, defence and critical infrastructure are far tighter, and securities firms are unusually looser.High confidence
What do I have to do to send it abroad?: There is no form to file and no government permission to obtain. You either send the data to a country the law already treats as safe, or you rely on one of five narrow exceptions. Those are: the person's clear consent, necessity for a contract made for that person's benefit, protecting someone's life, an important public interest or a legal claim, and the sender giving guarantees that private and family life will not be interfered with. That last one is a catch-all that a lot of Ukrainian practice leans on.High confidence
Who enforces this — and are they actually working?: The Ukrainian Parliament Commissioner for Human Rights — the national ombudsman — is the data protection regulator, and it is genuinely working. It publishes a fresh inspection programme every three months; the one for July to September 2026 went up on 2 July 2026. It also publishes what it found, including a run of checks on the national electronic health system. The catch is the money: the regulator cannot fine anyone itself, it writes up a case and sends it to a court, and the maximum penalty is about $800.High confidence
How long must I keep it, and when must I delete it?: The floor comes from tax law. Companies must keep primary accounting documents and financial statements for 1,825 days — five years. Papers needed for transfer pricing checks run to 2,555 days, which is seven years. Everything else the tax authority may ask for runs 1,095 days, three years. The ceiling comes from the privacy law: you must delete personal data when the agreed storage period runs out, or when your relationship with the person ends, unless another law tells you to keep it.High confidence
What happens when something goes wrong?: This is the biggest surprise in Ukrainian law: if you lose personal data, there is no duty to tell the regulator and no duty to tell the people affected. The 2010 privacy law simply has no breach reporting clause. The only mandatory clocks sit in the cyber security regime, and they only bite if you run a state system or a piece of critical information infrastructure. Even there the law does not set the hours — it leaves the deadline to an order of the cyber agency.Medium confidence
What's the trap?: Five. (1) If a Ukrainian government body is the one deciding how personal data is used, only a Ukrainian state-owned or municipal company may handle that data for it — a private or foreign supplier is not allowed at all. (2) Misusing personal data is a crime, not just a fine, and repeat offences carry up to five years in prison. (3) The fines are aimed at named individuals and sole traders, not at companies. (4) Posting anything that shows where Ukrainian troops are carries five to eight years in prison. (5) Martial law lets the government limit the constitutional right to privacy that the whole system rests on.High confidence
What's about to change?: The date to watch is not a new law — it is the end of the war. Martial law was extended again on 13 July 2026 and now runs from 2 August 2026 for 90 days, so to about 31 October 2026. Several of today's permissions exist only while it lasts, and they die six months after it ends. A European-style replacement privacy law has been discussed for years and has still not been passed, so nothing about the current regime should be planned around its arrival.High confidence
Hardest industry wall: Government — Закон України "Про захист персональних даних", частина третя статті 4
Government — Закон України "Про захист інформації в інформаційно-комунікаційних системах"
Defence — Закон України "Про хмарні послуги"
Mapping and location — Кримінальний кодекс України, стаття 114-2

The eight framework questions answered for each selected country
Question	South KoreaChecked 18 August 2026	UkraineChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Aggressive	Depends on your industry Work: Medium Enforcement: Active
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.	Ukraine still runs its 2010 privacy law, not a European-style one. Personal data may leave the country only to a country the law treats as safe — that means Europe and the 50-odd countries that signed a Council of Europe data treaty. The United States is not on that list. Fines are tiny, but the human rights Commissioner really does inspect, and misusing data can be a crime.
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.	The general picture changes completely once government is involved. If a Ukrainian state body is the organisation deciding how personal data is used, only a Ukrainian state-owned or municipal company may process that data for it — a private or foreign supplier cannot. State systems, defence data and critical infrastructure also carry hard location rules, and several of the current permissions exist only because the country is under martial law.
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	Probably not, if you have nothing in Ukraine. The 2010 law simply says it covers the processing of personal data by automated means or in structured paper files. It contains no clause reaching foreign companies that only sell into Ukraine from abroad, and it does not make you appoint a local representative. There is no size or revenue threshold either — a corner shop and a bank are treated the same.Medium 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	Yes, but only to countries Ukraine already treats as safe. Those are the European Economic Area countries plus every country that has signed the Council of Europe's data protection treaty — roughly 55 states. The United States has signed neither, so routine transfers to American servers do not fit the safe-country route and need one of the narrow exceptions instead. Whole sectors then override this: government, defence and critical infrastructure are far tighter, and securities firms are unusually looser.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	There is no form to file and no government permission to obtain. You either send the data to a country the law already treats as safe, or you rely on one of five narrow exceptions. Those are: the person's clear consent, necessity for a contract made for that person's benefit, protecting someone's life, an important public interest or a legal claim, and the sender giving guarantees that private and family life will not be interfered with. That last one is a catch-all that a lot of Ukrainian practice leans on.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	The Ukrainian Parliament Commissioner for Human Rights — the national ombudsman — is the data protection regulator, and it is genuinely working. It publishes a fresh inspection programme every three months; the one for July to September 2026 went up on 2 July 2026. It also publishes what it found, including a run of checks on the national electronic health system. The catch is the money: the regulator cannot fine anyone itself, it writes up a case and sends it to a court, and the maximum penalty is about $800.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	The floor comes from tax law. Companies must keep primary accounting documents and financial statements for 1,825 days — five years. Papers needed for transfer pricing checks run to 2,555 days, which is seven years. Everything else the tax authority may ask for runs 1,095 days, three years. The ceiling comes from the privacy law: you must delete personal data when the agreed storage period runs out, or when your relationship with the person ends, unless another law tells you to keep it.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	This is the biggest surprise in Ukrainian law: if you lose personal data, there is no duty to tell the regulator and no duty to tell the people affected. The 2010 privacy law simply has no breach reporting clause. The only mandatory clocks sit in the cyber security regime, and they only bite if you run a state system or a piece of critical information infrastructure. Even there the law does not set the hours — it leaves the deadline to an order of the cyber agency.Medium 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	Five. (1) If a Ukrainian government body is the one deciding how personal data is used, only a Ukrainian state-owned or municipal company may handle that data for it — a private or foreign supplier is not allowed at all. (2) Misusing personal data is a crime, not just a fine, and repeat offences carry up to five years in prison. (3) The fines are aimed at named individuals and sole traders, not at companies. (4) Posting anything that shows where Ukrainian troops are carries five to eight years in prison. (5) Martial law lets the government limit the constitutional right to privacy that the whole system rests on.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	The date to watch is not a new law — it is the end of the war. Martial law was extended again on 13 July 2026 and now runs from 2 August 2026 for 90 days, so to about 31 October 2026. Several of today's permissions exist only while it lasts, and they die six months after it ends. A European-style replacement privacy law has been discussed for years and has still not been passed, so nothing about the current regime should be planned around its arrival.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)	Government — Закон України "Про захист персональних даних", частина третя статті 4 Government — Закон України "Про захист інформації в інформаційно-комунікаційних системах" Defence — Закон України "Про хмарні послуги" Mapping and location — Кримінальний кодекс України, стаття 114-2