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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)

NetherlandsChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Aggressive

In one paragraph: For most businesses the Netherlands follows the ordinary European rules: data may leave the country once you have the right paperwork in place. Two areas are much harder. Online gambling firms must keep their regulator-facing database physically in the Netherlands, and central government now has to keep all its information inside Europe. The Dutch privacy regulator hands out some of the largest transfer fines in Europe.
The catch: The relaxed headline stops being true the moment you touch online gambling, central government work, health records or a regulated financial firm. An online gambling licence forces one database onto Dutch soil. Central government contracts now bar storage outside Europe. And a brand-new cybersecurity law switched on three days ago, on 15 August 2026, with a 24-hour incident alarm most companies have not built yet.
Does this apply to me?: Yes, it reaches you with no Dutch office. Europe's privacy law applies to any organisation anywhere that offers goods or services to people in the Netherlands or watches what they do online, and there is no size or revenue floor. Separately, the new Dutch cybersecurity law says that if you are a cloud provider, data centre, managed service provider, online marketplace, search engine or social network based outside Europe but selling into the Netherlands, you must appoint a representative inside the European Union.High confidence
Can the data leave the country?: In general yes, with paperwork, because the Netherlands is an EU country and European rules govern transfers. But three Dutch walls override that. An online gambling licence holder must physically place its regulator-facing control database in the Netherlands. Central government must keep all its information inside the European Economic Area plus Switzerland. And a healthcare provider, bank or insurer can put data abroad only if the supervisor can still see and audit it.High confidence
What do I have to do to send it abroad?: The model is an allowlist run at European level, not a Dutch one. You may send personal data outside Europe only if the destination has been officially approved, or you sign the standard European contract, or you use approved group-wide rules. The approved list is full and active. The Netherlands adds no national approval step and keeps no blocklist of its own.High confidence
Who enforces this — and are they actually working?: The Dutch Data Protection Authority, and it is very much operational and very much willing to fine. It has a full three-person board, and a new chair, Geert Potjewijd, took office on 1 August 2026. It has issued two of the largest cross-border transfer fines in Europe: 290 million euros against Uber in 2024 and 100 million euros against a taxi app in May 2026. Cybersecurity is enforced separately, by sector ministries and inspectorates, and that machinery is only now being assembled.High confidence
How long must I keep it, and when must I delete it?: There is a firm floor and a soft ceiling. You must keep your books and tax records for seven years, and money-laundering records for five years after the relationship or transaction ends. Against that, privacy law says you must delete personal data once you no longer need it, and there is no fixed number. When the two collide, the legal duty to keep wins for as long as it lasts, and deletion follows immediately after.High confidence
What happens when something goes wrong?: Count three clocks, not one. For a personal data breach you have 72 hours to tell the Dutch Data Protection Authority. If you are covered by the new cybersecurity law that started on 15 August 2026, you must raise an early warning within 24 hours, file a full report within 72 hours, and deliver a final report within one month. Telecom operators have a fourth clock and must tell the privacy regulator without delay.High confidence
What's the trap?: Five things that are not in the summary. Your works council can block an HR or monitoring system. Breaking a professional secrecy duty is a crime, not a fine. The telecom retention duty printed in the law cannot be enforced. Children need a parent's permission until they turn sixteen. And the new cybersecurity law started on 15 August 2026 with a phased exception for universities that most checklists miss.High confidence
What's about to change?: Three dated changes. On 1 September 2026 an amendment act tidies up the Dutch privacy law and adds new rules for handing over health files, but one part of it has deliberately been left switched off. Registration and incident duties under the cybersecurity law that started on 15 August 2026 are being phased in now. And by 12 January 2027 every cloud provider must drop switching and data export charges to zero across Europe.High confidence
Hardest industry wall: Online gaming — Besluit kansspelen op afstand, artikel 4.42, tweede lid
Government — Herziening rijksbreed cloudbeleid 2026

The eight framework questions answered for each selected country
Question	SloveniaChecked 18 August 2026	NetherlandsChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Active	Depends on your industry Work: High Enforcement: Aggressive
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.	For most businesses the Netherlands follows the ordinary European rules: data may leave the country once you have the right paperwork in place. Two areas are much harder. Online gambling firms must keep their regulator-facing database physically in the Netherlands, and central government now has to keep all its information inside Europe. The Dutch privacy regulator hands out some of the largest transfer fines in Europe.
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.	The relaxed headline stops being true the moment you touch online gambling, central government work, health records or a regulated financial firm. An online gambling licence forces one database onto Dutch soil. Central government contracts now bar storage outside Europe. And a brand-new cybersecurity law switched on three days ago, on 15 August 2026, with a 24-hour incident alarm most companies have not built yet.
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	Yes, it reaches you with no Dutch office. Europe's privacy law applies to any organisation anywhere that offers goods or services to people in the Netherlands or watches what they do online, and there is no size or revenue floor. Separately, the new Dutch cybersecurity law says that if you are a cloud provider, data centre, managed service provider, online marketplace, search engine or social network based outside Europe but selling into the Netherlands, you must appoint a representative inside the European Union.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	In general yes, with paperwork, because the Netherlands is an EU country and European rules govern transfers. But three Dutch walls override that. An online gambling licence holder must physically place its regulator-facing control database in the Netherlands. Central government must keep all its information inside the European Economic Area plus Switzerland. And a healthcare provider, bank or insurer can put data abroad only if the supervisor can still see and audit it.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	The model is an allowlist run at European level, not a Dutch one. You may send personal data outside Europe only if the destination has been officially approved, or you sign the standard European contract, or you use approved group-wide rules. The approved list is full and active. The Netherlands adds no national approval step and keeps no blocklist of its own.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	The Dutch Data Protection Authority, and it is very much operational and very much willing to fine. It has a full three-person board, and a new chair, Geert Potjewijd, took office on 1 August 2026. It has issued two of the largest cross-border transfer fines in Europe: 290 million euros against Uber in 2024 and 100 million euros against a taxi app in May 2026. Cybersecurity is enforced separately, by sector ministries and inspectorates, and that machinery is only now being assembled.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	There is a firm floor and a soft ceiling. You must keep your books and tax records for seven years, and money-laundering records for five years after the relationship or transaction ends. Against that, privacy law says you must delete personal data once you no longer need it, and there is no fixed number. When the two collide, the legal duty to keep wins for as long as it lasts, and deletion follows immediately after.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	Count three clocks, not one. For a personal data breach you have 72 hours to tell the Dutch Data Protection Authority. If you are covered by the new cybersecurity law that started on 15 August 2026, you must raise an early warning within 24 hours, file a full report within 72 hours, and deliver a final report within one month. Telecom operators have a fourth clock and must tell the privacy regulator without delay.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	Five things that are not in the summary. Your works council can block an HR or monitoring system. Breaking a professional secrecy duty is a crime, not a fine. The telecom retention duty printed in the law cannot be enforced. Children need a parent's permission until they turn sixteen. And the new cybersecurity law started on 15 August 2026 with a phased exception for universities that most checklists miss.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	Three dated changes. On 1 September 2026 an amendment act tidies up the Dutch privacy law and adds new rules for handing over health files, but one part of it has deliberately been left switched off. Registration and incident duties under the cybersecurity law that started on 15 August 2026 are being phased in now. And by 12 January 2027 every cloud provider must drop switching and data export charges to zero across Europe.High 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)	Online gaming — Besluit kansspelen op afstand, artikel 4.42, tweede lid Government — Herziening rijksbreed cloudbeleid 2026