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Two or three countries, side by side, one row per question. Pick up to 3.

Countries

RussiaChecked 18 August 2026

A copy must stayWork: Very highEnforcement: Active

In one paragraph: If you collect personal data from people in Russia, the database you collect it into must sit inside Russia. You may then send a copy abroad, but only after you tell the regulator first and only to a country on its approved list. The United States is not on that list. Breaking the storage rule costs up to 6 million roubles, about $75,000, and leaking data can now put a person in prison.
The catch: The 'copy may go abroad' part disappears in several industries. Payments, electronic money, biometrics, telecoms, internet messaging services, government systems and detailed mapping are hard walls: the data must stay in Russia and no copy may leave. Since 1 September 2025 any company running 'significant' critical infrastructure — which includes most banks, telecoms operators and large energy and health providers — must also run Russian-registered software on those systems.
Does this apply to me?: Yes. The law reaches a foreign company with no office in Russia. It applies whenever you process the personal data of Russian citizens under a contract with them, under any other agreement with them, or on the basis of their consent. There is no size or revenue threshold. Almost every organisation must also file a notice with the regulator before it starts processing, and file a second, separate notice before any data leaves the country.High confidence
Can the data leave the country?: A copy can leave, but the original must stay. When you collect personal data about Russian citizens, the database you record, store, update or retrieve it from has to be physically in Russia. Since 1 July 2025 the law says this as a flat ban on using databases outside Russia for those steps. After that, sending a copy abroad is a separate question with its own paperwork. Several industries are stricter still and allow no copy out at all.High confidence
What do I have to do to send it abroad?: Russia runs an approved-destinations list, so a transfer is banned unless the destination is on it. Before any data leaves you must send the regulator a separate written notice naming the countries, the data and the recipients, and you must first collect written assurances from the recipient about how it will protect the data. If the destination is on the approved list you may start as soon as the notice is sent. If it is not, you must wait, and in practice you will be refused. The United States is not on the list.High confidence
Who enforces this — and are they actually working?: Roskomnadzor, the federal communications and media supervisor, is the data protection regulator. It is a long-established federal service, fully staffed, and it is still issuing binding orders — its most recent inspection check-list order was published on the state legal portal in December 2025. It is not the only enforcer. The security service runs the national cyber-attack reporting system, the technical regulator FSTEC sets security requirements for government and critical systems, and the Bank of Russia supervises banks and payment firms.Medium confidence
How long must I keep it, and when must I delete it?: Both directions apply and they collide. Personal data must be destroyed within 30 days of the purpose being achieved, or within 30 days of consent being withdrawn, and within 10 working days if the processing was unlawful. Against that, staff records must be kept for 50 years, telecoms and messaging metadata for three years, and message content for up to six months. Where a statute sets a minimum, the minimum wins and you keep the data.High confidence
What happens when something goes wrong?: There are at least three clocks and they run at once. You have 24 hours to tell the data regulator that personal data has leaked, and 72 hours to give it the results of your internal investigation. Separately, if the leak came from a computer attack you must report it to the security service's national attack-detection system. Banks and payment firms report to the Bank of Russia as well. Missing the 24-hour notice is itself a fine of up to 3 million roubles, about $37,000.High confidence
What's the trap?: Five things catch people out. First, leaking data is now a crime, and doing it across a border carries up to eight years in prison. Second, repeat leaks are fined as a share of worldwide-style annual revenue, between 1 and 3 percent, with a floor of 20 million roubles, about $250,000. Third, staff files must be kept 50 years, which flatly conflicts with the 30-day deletion duty. Fourth, biometric data can only be handled by a Russian-controlled company using databases in Russia. Fifth, refusing to serve a customer because they will not give biometrics is itself a fine.High confidence
What's about to change?: One dated change is already fixed: from 1 September 2027, Moscow's public bodies move onto a single city technology platform, which will pull a large volume of citizen data into one place. Much more important are the switches the government already holds and can flip with no consultation. The approved-country list can be cut by a single regulator order. Any transfer can be banned outright on security or economic grounds. And the rules for foreign use of Russian mapping technology have been written into the law but never issued.High confidence
Hardest industry wall: All industries — Федеральный закон от 27.07.2006 № 152-ФЗ «О персональных данных», статья 18 часть 5
All industries — Федеральный закон № 152-ФЗ, статья 21 часть 3.1 и статья 19 часть 12
All industries — Уголовный кодекс Российской Федерации, статья 272.1
Payments — Федеральный закон от 27.06.2011 № 161-ФЗ «О национальной платежной системе», статьи 12 и 16
All industries — Федеральный закон от 29.12.2022 № 572-ФЗ об идентификации и аутентификации с использованием биометрических персональных данных
Telecoms — Федеральный закон от 07.07.2003 № 126-ФЗ «О связи», статья 64; Федеральный закон от 27.07.2006 № 149-ФЗ, статья 10.1
Government — Приказ ФСТЭК России от 11.04.2025 № 117; Указ Президента РФ от 30.03.2022 № 166; Указ Президента РФ от 01.05.2022 № 250; Федеральный закон от 07.04.2025 № 58-ФЗ
Mapping and location — Федеральный закон от 30.12.2015 № 431-ФЗ «О геодезии, картографии и пространственных данных», статьи 23 и 24
Health and social care — Федеральный закон от 21.11.2011 № 323-ФЗ «Об основах охраны здоровья граждан в Российской Федерации», статья 13
Social media and online platforms — Федеральный закон от 01.07.2021 № 236-ФЗ «О деятельности иностранных лиц в информационно-телекоммуникационной сети «Интернет» на территории Российской Федерации»

SwitzerlandChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Switzerland is easy to send data out of, as long as the destination is one the government trusts. An official list names about 44 approved places, including every European Union country and United States firms in one certification scheme. Anywhere else, you sign an approved contract first. The sting is elsewhere: getting it wrong is a crime, and the case lands on a person, not the company.
The catch: The relaxed headline stops the moment you touch three areas. Electronic patient record data must physically sit in Switzerland. Banking client data is protected by a criminal secrecy law with a three-year prison ceiling. Doctors, lawyers, notaries, pharmacists, psychologists and nurses are under a near-identical criminal secrecy rule, and a normal supplier contract does not cure it. Financial market infrastructures also need the regulator's permission before outsourcing anything important.
Does this apply to me?: Yes. Swiss privacy law reaches any organisation whose activities have an effect in Switzerland, even one with no office, staff or company here. There is no revenue or headcount threshold to duck under, and there is no register to sign up to. You only need a named representative inside Switzerland if four things are true at once: you are selling to people here or watching what they do, you are doing it on a large scale, you are doing it regularly, and the processing is high risk for the people involved. Very few foreign companies meet all four.High confidence
Can the data leave the country?: In general, yes. Switzerland publishes an official list of countries and territories it considers safe, and data can move to any of them with no extra paperwork. The list has about 44 entries. It covers all 27 European Union countries, the United Kingdom, Norway, Iceland, Liechtenstein, Canada, Israel, Argentina, Uruguay and New Zealand. It covers the United States only for companies signed up to one specific certification scheme. Japan is not on it, even though the European Union treats Japan as safe. For anywhere not on the list, you sign an approved contract first. But three industries override this completely, and one of them is an outright ban.High confidence
What do I have to do to send it abroad?: The model is an approved-destinations list, and it is well populated: about 44 countries, territories and one sector-specific entry are on it right now. Send data to a listed place and you need nothing at all. Send it anywhere else and you need one of a short menu of safeguards, the most common being a standard contract. Switzerland has formally accepted the European Union's standard contract template, so most companies can reuse the paperwork they already have.High confidence
Who enforces this — and are they actually working?: The main regulator is the Federal Data Protection and Information Commissioner. It is real, fully staffed and busy: in the year to 31 March 2026 it ran 156 low-level interventions, 22 preliminary enquiries and 9 formal investigations, and it had 2 cases running in the Federal Administrative Court. It has issued binding orders against a bank, a debt collection firm and a fashion group, and in October 2025 the court confirmed its new way of working. The catch is that this regulator cannot fine anyone. Fines under the privacy law are criminal, they are handed out by cantonal prosecutors, and they land on individual people.High confidence
How long must I keep it, and when must I delete it?: Both directions apply and they pull against each other. The floor: business books, accounting records and audit reports must be kept for ten years. Financial market infrastructures keep their records ten years, trade repositories keep trade data ten years after the contract matures, electronic patient record access logs are kept ten years, and telecoms companies keep connection records for six months. The ceiling: the privacy law says personal data must be destroyed or made anonymous as soon as it is no longer needed. There is no fixed number. Where the two clash, the specific legal duty to keep wins.High confidence
What happens when something goes wrong?: Count four clocks, not one. The privacy regulator must be told 'as quickly as possible' when a breach is likely to put people at serious risk, with no number of hours attached. If you run critical infrastructure, you have a hard 24 hours to tell the national cyber security office. If you are supervised by the financial regulator, you have 24 hours to notify your supervisor and 72 hours to file the full report. Electronic patient record communities have to report security incidents to the health office. Most failures come from teams who set a single deadline and miss the others.High confidence
What's the trap?: Five things that are not in the summary. One: the penalty is a criminal fine on a named human being, not an administrative fine on the company, so your compliance lead is personally exposed. Two: sending data abroad without a valid safeguard is itself a crime. Three: banking secrecy and medical or legal secrecy are criminal laws with prison ceilings, and a standard supplier contract does not fix them. Four: cantonal authorities and cantonal hospitals are outside the federal law entirely. Five: the 24-hour cyber report has no penalty for being late, which misleads people into thinking it is optional.High confidence
What's about to change?: Nothing in the next twelve months changes where Swiss data may be stored. The electronic identity law has passed but is not switched on yet, and the financial regulator is holding a rule change until it is. A company transparency law hits banks on 1 October 2026. A rewrite of the telecoms surveillance rules has been announced for years and still has not landed. The bigger risk is not new legislation at all: the government can rewrite the approved-destinations list by itself, overnight, with no vote and no consultation.Medium confidence
Hardest industry wall: Health and social care — Verordnung ueber das elektronische Patientendossier (EPDV)
Finance — FINMA-Rundschreiben 2018/3 'Outsourcing - Banken, Versicherungsunternehmen und ausgewaehlte Finanzinstitute nach FINIG'

The eight framework questions answered for each selected country
Question	RussiaChecked 18 August 2026	SwitzerlandChecked 18 August 2026
The three ratings	A copy must stay Work: Very high Enforcement: Active	Depends on your industry Work: Medium Enforcement: Active
In one paragraph	If you collect personal data from people in Russia, the database you collect it into must sit inside Russia. You may then send a copy abroad, but only after you tell the regulator first and only to a country on its approved list. The United States is not on that list. Breaking the storage rule costs up to 6 million roubles, about $75,000, and leaking data can now put a person in prison.	Switzerland is easy to send data out of, as long as the destination is one the government trusts. An official list names about 44 approved places, including every European Union country and United States firms in one certification scheme. Anywhere else, you sign an approved contract first. The sting is elsewhere: getting it wrong is a crime, and the case lands on a person, not the company.
The catch	The 'copy may go abroad' part disappears in several industries. Payments, electronic money, biometrics, telecoms, internet messaging services, government systems and detailed mapping are hard walls: the data must stay in Russia and no copy may leave. Since 1 September 2025 any company running 'significant' critical infrastructure — which includes most banks, telecoms operators and large energy and health providers — must also run Russian-registered software on those systems.	The relaxed headline stops the moment you touch three areas. Electronic patient record data must physically sit in Switzerland. Banking client data is protected by a criminal secrecy law with a three-year prison ceiling. Doctors, lawyers, notaries, pharmacists, psychologists and nurses are under a near-identical criminal secrecy rule, and a normal supplier contract does not cure it. Financial market infrastructures also need the regulator's permission before outsourcing anything important.
Does this apply to me?	Yes. The law reaches a foreign company with no office in Russia. It applies whenever you process the personal data of Russian citizens under a contract with them, under any other agreement with them, or on the basis of their consent. There is no size or revenue threshold. Almost every organisation must also file a notice with the regulator before it starts processing, and file a second, separate notice before any data leaves the country.High confidence	Yes. Swiss privacy law reaches any organisation whose activities have an effect in Switzerland, even one with no office, staff or company here. There is no revenue or headcount threshold to duck under, and there is no register to sign up to. You only need a named representative inside Switzerland if four things are true at once: you are selling to people here or watching what they do, you are doing it on a large scale, you are doing it regularly, and the processing is high risk for the people involved. Very few foreign companies meet all four.High confidence
Can the data leave the country?	A copy can leave, but the original must stay. When you collect personal data about Russian citizens, the database you record, store, update or retrieve it from has to be physically in Russia. Since 1 July 2025 the law says this as a flat ban on using databases outside Russia for those steps. After that, sending a copy abroad is a separate question with its own paperwork. Several industries are stricter still and allow no copy out at all.High confidence	In general, yes. Switzerland publishes an official list of countries and territories it considers safe, and data can move to any of them with no extra paperwork. The list has about 44 entries. It covers all 27 European Union countries, the United Kingdom, Norway, Iceland, Liechtenstein, Canada, Israel, Argentina, Uruguay and New Zealand. It covers the United States only for companies signed up to one specific certification scheme. Japan is not on it, even though the European Union treats Japan as safe. For anywhere not on the list, you sign an approved contract first. But three industries override this completely, and one of them is an outright ban.High confidence
What do I have to do to send it abroad?	Russia runs an approved-destinations list, so a transfer is banned unless the destination is on it. Before any data leaves you must send the regulator a separate written notice naming the countries, the data and the recipients, and you must first collect written assurances from the recipient about how it will protect the data. If the destination is on the approved list you may start as soon as the notice is sent. If it is not, you must wait, and in practice you will be refused. The United States is not on the list.High confidence	The model is an approved-destinations list, and it is well populated: about 44 countries, territories and one sector-specific entry are on it right now. Send data to a listed place and you need nothing at all. Send it anywhere else and you need one of a short menu of safeguards, the most common being a standard contract. Switzerland has formally accepted the European Union's standard contract template, so most companies can reuse the paperwork they already have.High confidence
Who enforces this — and are they actually working?	Roskomnadzor, the federal communications and media supervisor, is the data protection regulator. It is a long-established federal service, fully staffed, and it is still issuing binding orders — its most recent inspection check-list order was published on the state legal portal in December 2025. It is not the only enforcer. The security service runs the national cyber-attack reporting system, the technical regulator FSTEC sets security requirements for government and critical systems, and the Bank of Russia supervises banks and payment firms.Medium confidence	The main regulator is the Federal Data Protection and Information Commissioner. It is real, fully staffed and busy: in the year to 31 March 2026 it ran 156 low-level interventions, 22 preliminary enquiries and 9 formal investigations, and it had 2 cases running in the Federal Administrative Court. It has issued binding orders against a bank, a debt collection firm and a fashion group, and in October 2025 the court confirmed its new way of working. The catch is that this regulator cannot fine anyone. Fines under the privacy law are criminal, they are handed out by cantonal prosecutors, and they land on individual people.High confidence
How long must I keep it, and when must I delete it?	Both directions apply and they collide. Personal data must be destroyed within 30 days of the purpose being achieved, or within 30 days of consent being withdrawn, and within 10 working days if the processing was unlawful. Against that, staff records must be kept for 50 years, telecoms and messaging metadata for three years, and message content for up to six months. Where a statute sets a minimum, the minimum wins and you keep the data.High confidence	Both directions apply and they pull against each other. The floor: business books, accounting records and audit reports must be kept for ten years. Financial market infrastructures keep their records ten years, trade repositories keep trade data ten years after the contract matures, electronic patient record access logs are kept ten years, and telecoms companies keep connection records for six months. The ceiling: the privacy law says personal data must be destroyed or made anonymous as soon as it is no longer needed. There is no fixed number. Where the two clash, the specific legal duty to keep wins.High confidence
What happens when something goes wrong?	There are at least three clocks and they run at once. You have 24 hours to tell the data regulator that personal data has leaked, and 72 hours to give it the results of your internal investigation. Separately, if the leak came from a computer attack you must report it to the security service's national attack-detection system. Banks and payment firms report to the Bank of Russia as well. Missing the 24-hour notice is itself a fine of up to 3 million roubles, about $37,000.High confidence	Count four clocks, not one. The privacy regulator must be told 'as quickly as possible' when a breach is likely to put people at serious risk, with no number of hours attached. If you run critical infrastructure, you have a hard 24 hours to tell the national cyber security office. If you are supervised by the financial regulator, you have 24 hours to notify your supervisor and 72 hours to file the full report. Electronic patient record communities have to report security incidents to the health office. Most failures come from teams who set a single deadline and miss the others.High confidence
What's the trap?	Five things catch people out. First, leaking data is now a crime, and doing it across a border carries up to eight years in prison. Second, repeat leaks are fined as a share of worldwide-style annual revenue, between 1 and 3 percent, with a floor of 20 million roubles, about $250,000. Third, staff files must be kept 50 years, which flatly conflicts with the 30-day deletion duty. Fourth, biometric data can only be handled by a Russian-controlled company using databases in Russia. Fifth, refusing to serve a customer because they will not give biometrics is itself a fine.High confidence	Five things that are not in the summary. One: the penalty is a criminal fine on a named human being, not an administrative fine on the company, so your compliance lead is personally exposed. Two: sending data abroad without a valid safeguard is itself a crime. Three: banking secrecy and medical or legal secrecy are criminal laws with prison ceilings, and a standard supplier contract does not fix them. Four: cantonal authorities and cantonal hospitals are outside the federal law entirely. Five: the 24-hour cyber report has no penalty for being late, which misleads people into thinking it is optional.High confidence
What's about to change?	One dated change is already fixed: from 1 September 2027, Moscow's public bodies move onto a single city technology platform, which will pull a large volume of citizen data into one place. Much more important are the switches the government already holds and can flip with no consultation. The approved-country list can be cut by a single regulator order. Any transfer can be banned outright on security or economic grounds. And the rules for foreign use of Russian mapping technology have been written into the law but never issued.High confidence	Nothing in the next twelve months changes where Swiss data may be stored. The electronic identity law has passed but is not switched on yet, and the financial regulator is holding a rule change until it is. A company transparency law hits banks on 1 October 2026. A rewrite of the telecoms surveillance rules has been announced for years and still has not landed. The bigger risk is not new legislation at all: the government can rewrite the approved-destinations list by itself, overnight, with no vote and no consultation.Medium confidence
Hardest industry wall	All industries — Федеральный закон от 27.07.2006 № 152-ФЗ «О персональных данных», статья 18 часть 5 All industries — Федеральный закон № 152-ФЗ, статья 21 часть 3.1 и статья 19 часть 12 All industries — Уголовный кодекс Российской Федерации, статья 272.1 Payments — Федеральный закон от 27.06.2011 № 161-ФЗ «О национальной платежной системе», статьи 12 и 16 All industries — Федеральный закон от 29.12.2022 № 572-ФЗ об идентификации и аутентификации с использованием биометрических персональных данных Telecoms — Федеральный закон от 07.07.2003 № 126-ФЗ «О связи», статья 64; Федеральный закон от 27.07.2006 № 149-ФЗ, статья 10.1 Government — Приказ ФСТЭК России от 11.04.2025 № 117; Указ Президента РФ от 30.03.2022 № 166; Указ Президента РФ от 01.05.2022 № 250; Федеральный закон от 07.04.2025 № 58-ФЗ Mapping and location — Федеральный закон от 30.12.2015 № 431-ФЗ «О геодезии, картографии и пространственных данных», статьи 23 и 24 Health and social care — Федеральный закон от 21.11.2011 № 323-ФЗ «Об основах охраны здоровья граждан в Российской Федерации», статья 13 Social media and online platforms — Федеральный закон от 01.07.2021 № 236-ФЗ «О деятельности иностранных лиц в информационно-телекоммуникационной сети «Интернет» на территории Российской Федерации»	Health and social care — Verordnung ueber das elektronische Patientendossier (EPDV) Finance — FINMA-Rundschreiben 2018/3 'Outsourcing - Banken, Versicherungsunternehmen und ausgewaehlte Finanzinstitute nach FINIG'