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SloveniaChecked 18 August 2026
Depends on your industryWork: HighEnforcement: Active
In one paragraph
Slovenia has no general rule that data must stay in the country. It runs on the European rulebook: send data abroad once you have the right paperwork. Three things break that. The company running the new national health record system may not store data outside Slovenia. Government bodies may cloud only their least sensitive data. And working-time records must sit at the Slovenian workplace.
The catch
The easy answer stops being true in four places. First, health: the state-owned company running the central health information system is forbidden by law from transferring or storing personal data outside Slovenian territory, and every healthcare provider in the country must plug into that system. Second, government: a state administration body may only use a public cloud for the lowest security tiers of information, and only after the ministry approves in writing. Third, employment: the record of working time and the documents behind it must be kept at the employer's registered office or at the place where the worker actually works. Fourth, gambling: only a joint-stock company registered in Slovenia can hold a concession, and its system must be wired into the tax authority's own system. Banking, payments, insurance, securities, telecoms and mapping have no storage-location rule that we could find.
Does this apply to me?
Yes. Slovenia's privacy rules reach a company with no office there. If you offer goods or services to people in Slovenia, or watch what they do online, the European rules apply to you and Slovenia's own privacy act applies alongside them. There is no size or revenue threshold that lets you out. A company with no office anywhere in Europe must appoint a written representative inside Europe.High confidence
Can the data leave the country?
In general yes, with paperwork — Slovenia adds no national storage-location rule of its own on top of the European regime. But four industries break that answer, and one of them is a hard wall. Health is the big one: the state company that runs Slovenia's central health record system is banned outright from storing or sending personal data outside Slovenia, and every healthcare provider must connect to that system. Government cloud, employment records and gambling each carry their own restriction.High confidence
What do I have to do to send it abroad?
Slovenia uses the European model, and it works like an approved-destinations list with escape hatches. Data may go to a country the European Commission has approved. If the destination is not approved, you can still send data by signing the Commission's standard contract, using approved group-wide rules, or relying on one of a few narrow exceptions. Slovenia adds nothing of its own. The old Slovenian system, where the Information Commissioner had to authorise each export, was scrapped when the current privacy act arrived in January 2023.High confidence
Who enforces this — and are they actually working?
The Information Commissioner, and it is genuinely working. In 2025 it opened 464 inspection cases from complaints plus 102 more from inspection reports, issued 134 enforcement decisions, fined in 89 of them, gave warnings in 45, and handed down what it calls its largest fine since the European rules began. It handled 153 breach reports. It is small: one commissioner and 53 staff at the end of 2025, and it says openly that it does not have enough people. Cybersecurity is enforced separately by a government office set up for the job.High confidence
How long must I keep it, and when must I delete it?
Both directions, and the floors are long. A patient's medical file must be kept for ten years after the patient dies, and other basic medical records for fifteen years. Records of who touched personal data in a computer system must be kept for two years after the end of the year, and up to five if the risk is high. Working-time records must be kept at the Slovenian workplace. In the other direction the European rule applies: delete personal data once the purpose is spent.High confidence
What happens when something goes wrong?
Count three clocks, not one. A personal data breach goes to the Information Commissioner within 72 hours. A serious cyber incident, if you are an essential or important organisation, goes to the government security office immediately and in any case within 24 hours as an early warning, then a full report within 72 hours, then a final report within one month. Telecoms operators have their own duties on top. Missing the 24-hour warning is the most common failure, because it lands while you are still working out what happened.High confidence
What's the trap?
Five things that catch people out. A child can consent at 15 in Slovenia, not 16 — one year younger than the European default. Fingerprints and face scans are banned in the private sector unless a law allows them and the Commissioner approves. Every access to a covered database must be logged and the log kept two years. Leaking personal data you got through your job is a crime, not just a fine. And working-time records must physically be at the Slovenian workplace, which no cloud contract fixes.High confidence
What's about to change?
Two dates in the next twelve months matter most. On 19 December 2026 the cybersecurity duties bite for organisations newly captured by Slovenia's 2025 Information Security Act — registration, security measures and the incident clocks. On 12 January 2027 the European Data Act bans all cloud switching and data export fees. Behind both sits the roll-out of the national health record system, whose ban on storing data outside Slovenia is already law but whose timetable we could not pin down.Medium confidence
Hardest industry wall
  • Health and social care Zakon o digitalizaciji zdravstva (ZDigZ)
  • All industries Zakon o spremembah in dopolnitvah Zakona o evidencah na področju dela in socialne varnosti (ZEPDSV-A)
IcelandChecked 18 August 2026
Depends on your industryWork: HighEnforcement: Active
In one paragraph
Iceland follows Europe's privacy rulebook, so personal data can leave the country once the right paperwork is in place. Two local rules surprise people: a company's accounting records must physically be kept in Iceland, and health record systems can only be hosted by a certified provider. The privacy regulator is small but genuinely busy, and it fines public bodies too.
The catch
The relaxed answer is true for personal data only. Iceland's bookkeeping law says a company's books, invoices and receipts must be kept in Iceland for seven years, and only lets you hold them abroad for up to six months — and breaking the bookkeeping law is a crime, not a fine from the privacy regulator. Health record hosting has its own certification wall. Separately, three European laws that people assume apply here — the Data Act, the cybersecurity law known as NIS2, and the Artificial Intelligence Act — have NOT yet been brought into Icelandic law, so the rights and deadlines they create do not exist in Iceland today.
Does this apply to me?
Yes, it reaches you with no office in Iceland. Iceland applies Europe's General Data Protection Regulation through the European Economic Area agreement, so the rules cover any organisation anywhere in the world that offers goods or services to people in Iceland, or that watches what they do. There is no size or revenue threshold to duck under. If your organisation has no establishment anywhere in Europe, you normally have to name a representative inside Europe who people and the regulator can contact.High confidence
Can the data leave the country?
For personal data, yes — it can leave once you have the right paperwork. Two Icelandic rules cut across that headline. First, your company's accounting books, invoices and receipts must be kept in Iceland for seven years; the law only lets you hold them abroad for up to six months. Second, a health record system can sit with an outside host only if that host holds a recognised security certificate and the normal rules for sending data out of Europe are met.Medium confidence
What do I have to do to send it abroad?
You use one of the standard European routes. Send the data to a country Europe has officially approved, or sign the European Commission's standard contract with the recipient, or use group-wide rules a regulator has approved. Narrow one-off exceptions exist, such as the person's explicit consent, but they are not for routine or bulk transfers. One Icelandic wrinkle catches people out: an approval of a foreign country only takes effect in Iceland once the Icelandic minister confirms it and publishes a notice in the official gazette.Medium confidence
Who enforces this — and are they actually working?
Persónuvernd, the Icelandic Data Protection Authority. It is genuinely operational, not a name on paper: it registered 2,124 new cases in 2025 and closed 2,232, it opens its own investigations without waiting for a complaint, and it fines public bodies as well as private companies. It is also small — about 17 staff and a budget of roughly 379 million krónur (about $2.8 million) — and it says in its own annual report that it cannot cover every task the law gives it.High confidence
How long must I keep it, and when must I delete it?
There is a floor and a ceiling, and they point in opposite directions. The floor: accounting books, invoices and receipts must be kept for seven years — and kept in Iceland. The ceiling: under the European rules you must delete personal data once you no longer need it for the purpose you collected it for. When the two clash, the keeping duty wins; a person cannot force you to delete records the bookkeeping and tax law requires you to hold.High confidence
What happens when something goes wrong?
Count at least two clocks, and three if you are a financial firm. You have 72 hours to report a personal data breach to Persónuvernd, and you must tell the people affected without delay where the risk to them is high. Separately, operators of critical services — banks, hospitals, energy, water, transport and digital infrastructure — must alert Iceland's national cyber security team as soon as possible under a 2019 law, and serious breaches of that law can lead to prosecution. Financial firms have a further, tighter reporting duty to the Central Bank under the European operational resilience rules.Medium confidence
What's the trap?
Five things that are not in the summary. (1) A child in Iceland is anyone under 13 for online consent, not 16 as in much of Europe — so a design built for a 16-year-old threshold is wrong here. (2) Your accounting records must sit in Iceland, and bookkeeping offences are criminal: fines, and up to six years in prison for serious cases, investigated by the district prosecutor and the tax investigators, not by the privacy regulator. (3) Public bodies can be fined in Iceland — the law says so expressly, unlike several European countries. (4) Some processing needs a licence from Persónuvernd before you start, which is unusual under the European regime. (5) Three European laws you may assume apply here do not yet: the Data Act, the cybersecurity law known as NIS2, and the Artificial Intelligence Act have not been brought into the European Economic Area agreement.High confidence
What's about to change?
The main thing to watch is not an Icelandic bill but the queue of European laws waiting to be pulled into Icelandic law. The Data Act, the cybersecurity law known as NIS2 and the Artificial Intelligence Act are all still outside the European Economic Area agreement as of 18 August 2026, and each will land when a joint committee decides — with no Icelandic public consultation and often at short notice. The financial resilience regulation already landed this way on 1 July 2025, more than five months after it started applying in the European Union.High confidence
Hardest industry wall
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