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Countries

MongoliaChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Waking up

In one paragraph: Mongolia is not an open country for data. As a rule you may not send personal data abroad at all unless the person agrees or a law says you can. On top of that, a 2023 ministry order says that any server handling sensitive data must sit in Mongolia and must be reachable only from inside Mongolia. Sensitive data is defined very widely and includes health records and the content of messages.
The catch: Do not read 'depends on your industry' as 'open in general'. The baseline is already a ban with a consent exception. The hard walls are drawn by data type as much as by industry: health data, biometrics, genetic data, criminal records, digital signature keys and the content of letters, e-mail and messages all fall inside the server-in-Mongolia rule, whatever business you are in. Government bodies, state-owned and state-part-owned companies, and any company running a government service under a law or contract face a second wall over their databases.
Does this apply to me?: Probably not, if you have no presence in Mongolia at all. The privacy law says it governs how people, companies and unincorporated bodies collect, process and use personal data, but it does not say it reaches organisations outside the country. There is no revenue or size threshold, and there is no duty to appoint a local representative. In practice the rules bite through your Mongolian company, your Mongolian server, or your Mongolian licence rather than through long-arm reach.Medium confidence
Can the data leave the country?: Only sometimes, and for a lot of data the answer is a flat no. The general rule is that sending personal data to a person, company or international body abroad is banned unless a law or a treaty allows it, or the person the data is about has agreed. Then a separate ministry order takes health data, biometrics, genetic data, criminal records, digital signature keys and the content of letters, e-mail and messages out of reach entirely: the server has to be in Mongolia and has to be reachable only from Mongolia. Government systems and the country's foundational databases must also stay in Mongolia.High confidence
What do I have to do to send it abroad?: There is no approval process, no standard contract and no list of approved countries. Mongolia works the other way round: the transfer is banned, and the only ways out are a law or treaty that allows it, or the written consent of the person concerned. Consent is not a light-touch tick box. You must name every recipient before you collect the data, you must be able to prove the consent, and the person can withdraw it at any time.High confidence
Who enforces this — and are they actually working?: Nobody owns privacy on its own. The law splits the job three ways: the National Human Rights Commission handles complaints and supervision, the Ministry of Digital Development, Innovation and Communications writes the technical rules and takes cyber incident reports, and other state bodies police their own sectors. The ministry is clearly working: it has issued binding orders and it keeps a live register of 49 licensed information security auditors. What we could not find is any published privacy fine or decision, so treat the privacy side as switched on but not yet biting.Medium confidence
How long must I keep it, and when must I delete it?: Mongolia is unusual: the privacy law tells you when you may delete, not just when you must. You may only erase personal data on four listed grounds, and deleting it on any other ground is forbidden. Pulling the other way, payment businesses must keep their records for at least 15 years, anyone handling sensitive data must keep a history log of every change, deletion and restoration, and organisations running shared information systems must keep activity logs for a period fixed by government rules.High confidence
What happens when something goes wrong?: There are three clocks and none of them is measured in hours. The word the laws use is 'immediately', which they define as the shortest possible time. You tell the affected person immediately if the problem could harm them, you tell the ministry immediately if your system's security failed or you were attacked, and if you run critical national infrastructure you tell the national response centre immediately as well. Once a year, every January, you also send the human rights commission a register of the incidents you had and what you did about them.High confidence
What's the trap?: Five things catch people out. First, fingerprint scanners at work are illegal for private employers: an employer may use other biometrics with the worker's consent, but never fingerprints, and may not pass that biometric data to anyone else. Second, 'sensitive data' includes the content of letters, e-mail and messages, which drags ordinary company mail systems towards the server-in-Mongolia rule. Third, financial and payment data is not classed as sensitive, but a fingerprint or face login for a banking app is, so banks land inside the strict rules by the back door. Fourth, breaking the privacy law can be a crime, not just a fine. Fifth, if you build data storage or a content delivery network inside Mongolia you need a telecoms licence.High confidence
What's about to change?: One big thing is in motion. The government decided on 13 May 2026 to build a legal framework for putting data into economic circulation and reuse, and to prepare for a green, energy-efficient data centre in Mongolia. The ministry is now consulting on a first Data Law. It is a draft, so nothing in it binds anyone yet. The bigger short-term risk is not new legislation at all: the minister can rewrite the server and storage rules by a simple order, without parliament and without consultation.Medium confidence
Hardest industry wall: Health and social care — Хүний эмзэг мэдээлэл, генетик болон биометрик мэдээлэл боловсруулахад баримтлах технологийн аюулгүй байдлын шаардлага, журам
Government — Нийтийн мэдээллийн ил тод байдлын тухай хууль
Mapping and location — Нийтийн мэдээллийн ил тод байдлын тухай хууль, 27.3, 27.7 дугаар зүйл
All industries — Хүний хувийн мэдээлэл хамгаалах тухай хууль, 10, 31 дүгээр зүйл

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)

The eight framework questions answered for each selected country
Question	MongoliaChecked 18 August 2026	CanadaChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Waking up	Depends on your industry Work: High Enforcement: Active
In one paragraph	Mongolia is not an open country for data. As a rule you may not send personal data abroad at all unless the person agrees or a law says you can. On top of that, a 2023 ministry order says that any server handling sensitive data must sit in Mongolia and must be reachable only from inside Mongolia. Sensitive data is defined very widely and includes health records and the content of messages.	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	Do not read 'depends on your industry' as 'open in general'. The baseline is already a ban with a consent exception. The hard walls are drawn by data type as much as by industry: health data, biometrics, genetic data, criminal records, digital signature keys and the content of letters, e-mail and messages all fall inside the server-in-Mongolia rule, whatever business you are in. Government bodies, state-owned and state-part-owned companies, and any company running a government service under a law or contract face a second wall over their databases.	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?	Probably not, if you have no presence in Mongolia at all. The privacy law says it governs how people, companies and unincorporated bodies collect, process and use personal data, but it does not say it reaches organisations outside the country. There is no revenue or size threshold, and there is no duty to appoint a local representative. In practice the rules bite through your Mongolian company, your Mongolian server, or your Mongolian licence rather than through long-arm reach.Medium confidence	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?	Only sometimes, and for a lot of data the answer is a flat no. The general rule is that sending personal data to a person, company or international body abroad is banned unless a law or a treaty allows it, or the person the data is about has agreed. Then a separate ministry order takes health data, biometrics, genetic data, criminal records, digital signature keys and the content of letters, e-mail and messages out of reach entirely: the server has to be in Mongolia and has to be reachable only from Mongolia. Government systems and the country's foundational databases must also stay in Mongolia.High confidence	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?	There is no approval process, no standard contract and no list of approved countries. Mongolia works the other way round: the transfer is banned, and the only ways out are a law or treaty that allows it, or the written consent of the person concerned. Consent is not a light-touch tick box. You must name every recipient before you collect the data, you must be able to prove the consent, and the person can withdraw it at any time.High confidence	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?	Nobody owns privacy on its own. The law splits the job three ways: the National Human Rights Commission handles complaints and supervision, the Ministry of Digital Development, Innovation and Communications writes the technical rules and takes cyber incident reports, and other state bodies police their own sectors. The ministry is clearly working: it has issued binding orders and it keeps a live register of 49 licensed information security auditors. What we could not find is any published privacy fine or decision, so treat the privacy side as switched on but not yet biting.Medium confidence	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?	Mongolia is unusual: the privacy law tells you when you may delete, not just when you must. You may only erase personal data on four listed grounds, and deleting it on any other ground is forbidden. Pulling the other way, payment businesses must keep their records for at least 15 years, anyone handling sensitive data must keep a history log of every change, deletion and restoration, and organisations running shared information systems must keep activity logs for a period fixed by government rules.High confidence	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?	There are three clocks and none of them is measured in hours. The word the laws use is 'immediately', which they define as the shortest possible time. You tell the affected person immediately if the problem could harm them, you tell the ministry immediately if your system's security failed or you were attacked, and if you run critical national infrastructure you tell the national response centre immediately as well. Once a year, every January, you also send the human rights commission a register of the incidents you had and what you did about them.High confidence	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 catch people out. First, fingerprint scanners at work are illegal for private employers: an employer may use other biometrics with the worker's consent, but never fingerprints, and may not pass that biometric data to anyone else. Second, 'sensitive data' includes the content of letters, e-mail and messages, which drags ordinary company mail systems towards the server-in-Mongolia rule. Third, financial and payment data is not classed as sensitive, but a fingerprint or face login for a banking app is, so banks land inside the strict rules by the back door. Fourth, breaking the privacy law can be a crime, not just a fine. Fifth, if you build data storage or a content delivery network inside Mongolia you need a telecoms licence.High confidence	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 thing is in motion. The government decided on 13 May 2026 to build a legal framework for putting data into economic circulation and reuse, and to prepare for a green, energy-efficient data centre in Mongolia. The ministry is now consulting on a first Data Law. It is a draft, so nothing in it binds anyone yet. The bigger short-term risk is not new legislation at all: the minister can rewrite the server and storage rules by a simple order, without parliament and without consultation.Medium confidence	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	Health and social care — Хүний эмзэг мэдээлэл, генетик болон биометрик мэдээлэл боловсруулахад баримтлах технологийн аюулгүй байдлын шаардлага, журам Government — Нийтийн мэдээллийн ил тод байдлын тухай хууль Mapping and location — Нийтийн мэдээллийн ил тод байдлын тухай хууль, 27.3, 27.7 дугаар зүйл All industries — Хүний хувийн мэдээлэл хамгаалах тухай хууль, 10, 31 дүгээр зүйл	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)