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Countries

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)

United StatesChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
The catch: The open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
Does this apply to me?: Yes. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from Europe.High confidence
Can the data leave the country?: It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.High confidence
What do I have to do to send it abroad?: For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.High confidence
Who enforces this — and are they actually working?: Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.High confidence
How long must I keep it, and when must I delete it?: There is a strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.High confidence
What happens when something goes wrong?: Count the clocks — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.High confidence
What's the trap?: Five that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.High confidence
What's about to change?: Four things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.High confidence
Hardest industry wall: Government — Criminal Justice Information Services (CJIS) Security Policy
Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies
Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services
Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector

The eight framework questions answered for each selected country
Question	SloveniaChecked 18 August 2026	United StatesChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Active	Depends on your industry Work: High Enforcement: 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.	In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
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 open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
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. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from 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	It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.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	For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.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	Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.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 strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.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 the clocks — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.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 that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.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	Four things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.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)	Government — Criminal Justice Information Services (CJIS) Security Policy Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector