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

Countries

ThailandChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Active

In one paragraph: Thailand does not make you keep personal data inside the country, but data cannot leave until you have picked and documented a legal route. The regulator never published a list of approved destination countries, so consent and written safeguards do all the work. A foreign company selling into Thailand needs a named representative living there. Getting it wrong can mean fines, double damages, and in the worst cases jail.
The catch: The permissive headline is about residency only. The burden is high and the pain is elsewhere: a person in Thailand who answers for you personally, parental consent for anyone under twenty in many cases, 90-day traffic logs that catch any business offering guest wi-fi, compensation owed even when you were not careless, and a technology-crime regime that forces banks and telecoms companies to hand customer data into a government-run exchange. Payments, government workloads and digital platforms each add their own regulator gate on top.
Does this apply to me?: Yes. The privacy law reaches a company with no office in Thailand if it offers goods or services to people who are in Thailand, or if it tracks what those people do. Payment is irrelevant — a free service counts. There is no revenue or headcount floor to fall below. A foreign company caught this way must appoint, in writing, a representative who is physically in Thailand and who can be held answerable with no cap on liability.High confidence
Can the data leave the country?: Yes, in most cases. Thailand does not make companies keep a copy of personal data inside the country. But data cannot simply leave: you must first have a legal route, and the regulator has never published a list of approved destination countries, so the 'this country is safe enough' route is unusable in practice. Everyone falls back on informed consent, contract necessity, approved group-wide rules, or their own written safeguards. Several industries add a second gate on top, described below.High confidence
What do I have to do to send it abroad?: There is no permission slip to apply for and no banned-country list. You pick a route and document it before the data moves. The routes are: the destination is judged to have good enough protection; one of six statutory exceptions such as informed consent; group-wide rules certified by the regulator; or your own written safeguards that a person in Thailand could actually enforce. The 'good enough country' route is dead on arrival because the regulator has published no approved list, so in practice the safeguards route and consent do all the work.Medium confidence
Who enforces this — and are they actually working?: The Office of the Personal Data Protection Committee, usually shortened to PDPC, sits under the Ministry of Digital Economy and Society. It is real and staffed: it has a serving Secretary-General, it runs walk-in complaint centres in five provinces and opened another in Ubon Ratchathani on 17 August 2026, and it is executing Cabinet-level instructions on data breaches. Complaints are decided by an Expert Committee that can order you to stop, order you to fix things, and impose fines itself. Other regulators run their own lanes: the cyber-security agency for critical infrastructure, the central bank for payments, and the electronic transactions agency for digital platforms.Medium confidence
How long must I keep it, and when must I delete it?: Thailand pushes in both directions at once. The floor: anyone who provides a computer or internet service to other people must keep traffic logs for at least 90 days, and an official can order that stretched to as much as two years. The ceiling: the privacy law makes you build a system that actually deletes personal data once your stated retention period runs out or the data is no longer needed. When the two collide, the keep-it duty wins, because the delete duty has a written carve-out for complying with law and for defending legal claims.High confidence
What happens when something goes wrong?: Count three clocks, not one. First: tell the privacy regulator about a personal data breach without delay and within 72 hours of becoming aware, unless the breach carries no risk to people; if the risk to people is high you must also tell the affected individuals, with advice on what to do, without delay. Second: if you run critical information infrastructure, a significant cyber threat must be reported to the national cyber-security agency and to your own sector regulator, and silence without good reason is itself an offence. Third: if you are a bank or a telecoms operator and you suspect technology crime, you must push customer account and transaction data into a shared government-run system immediately.High confidence
What's the trap?: Five things that are not in the brochure. Children: Thailand needs a parent's consent for a child aged ten or under, and for older teenagers too unless the act is one the law lets a minor do alone — and a person is a minor in Thailand until twenty. Jail is on the table for misusing sensitive data. You owe compensation even if you were not careless, and a court can add up to double on top. A foreign company must put a named human in Thailand with unlimited authority. And the 90-day log rule catches ordinary businesses that just offer guest wi-fi.High confidence
What's about to change?: Nothing in the next twelve months looks like a new statute. What is moving is enforcement reach. The privacy regulator is opening walk-in centres in eight provinces during 2026 to cover all five regions, which means more complaints will actually get filed. The Cabinet decided on 11 August 2026 to require multi-factor login protection across government to stop leaked passwords turning into data breaches, and the ministry is pushing the same expectation across all twenty ministries. The bigger risk is not new law but switches the government already holds and can flip without warning.Medium confidence
Hardest industry wall: None found.

UkraineChecked 18 August 2026

Depends on your industryWork: MediumEnforcement: Active

In one paragraph: Ukraine still runs its 2010 privacy law, not a European-style one. Personal data may leave the country only to a country the law treats as safe — that means Europe and the 50-odd countries that signed a Council of Europe data treaty. The United States is not on that list. Fines are tiny, but the human rights Commissioner really does inspect, and misusing data can be a crime.
The catch: The general picture changes completely once government is involved. If a Ukrainian state body is the organisation deciding how personal data is used, only a Ukrainian state-owned or municipal company may process that data for it — a private or foreign supplier cannot. State systems, defence data and critical infrastructure also carry hard location rules, and several of the current permissions exist only because the country is under martial law.
Does this apply to me?: Probably not, if you have nothing in Ukraine. The 2010 law simply says it covers the processing of personal data by automated means or in structured paper files. It contains no clause reaching foreign companies that only sell into Ukraine from abroad, and it does not make you appoint a local representative. There is no size or revenue threshold either — a corner shop and a bank are treated the same.Medium confidence
Can the data leave the country?: Yes, but only to countries Ukraine already treats as safe. Those are the European Economic Area countries plus every country that has signed the Council of Europe's data protection treaty — roughly 55 states. The United States has signed neither, so routine transfers to American servers do not fit the safe-country route and need one of the narrow exceptions instead. Whole sectors then override this: government, defence and critical infrastructure are far tighter, and securities firms are unusually looser.High confidence
What do I have to do to send it abroad?: There is no form to file and no government permission to obtain. You either send the data to a country the law already treats as safe, or you rely on one of five narrow exceptions. Those are: the person's clear consent, necessity for a contract made for that person's benefit, protecting someone's life, an important public interest or a legal claim, and the sender giving guarantees that private and family life will not be interfered with. That last one is a catch-all that a lot of Ukrainian practice leans on.High confidence
Who enforces this — and are they actually working?: The Ukrainian Parliament Commissioner for Human Rights — the national ombudsman — is the data protection regulator, and it is genuinely working. It publishes a fresh inspection programme every three months; the one for July to September 2026 went up on 2 July 2026. It also publishes what it found, including a run of checks on the national electronic health system. The catch is the money: the regulator cannot fine anyone itself, it writes up a case and sends it to a court, and the maximum penalty is about $800.High confidence
How long must I keep it, and when must I delete it?: The floor comes from tax law. Companies must keep primary accounting documents and financial statements for 1,825 days — five years. Papers needed for transfer pricing checks run to 2,555 days, which is seven years. Everything else the tax authority may ask for runs 1,095 days, three years. The ceiling comes from the privacy law: you must delete personal data when the agreed storage period runs out, or when your relationship with the person ends, unless another law tells you to keep it.High confidence
What happens when something goes wrong?: This is the biggest surprise in Ukrainian law: if you lose personal data, there is no duty to tell the regulator and no duty to tell the people affected. The 2010 privacy law simply has no breach reporting clause. The only mandatory clocks sit in the cyber security regime, and they only bite if you run a state system or a piece of critical information infrastructure. Even there the law does not set the hours — it leaves the deadline to an order of the cyber agency.Medium confidence
What's the trap?: Five. (1) If a Ukrainian government body is the one deciding how personal data is used, only a Ukrainian state-owned or municipal company may handle that data for it — a private or foreign supplier is not allowed at all. (2) Misusing personal data is a crime, not just a fine, and repeat offences carry up to five years in prison. (3) The fines are aimed at named individuals and sole traders, not at companies. (4) Posting anything that shows where Ukrainian troops are carries five to eight years in prison. (5) Martial law lets the government limit the constitutional right to privacy that the whole system rests on.High confidence
What's about to change?: The date to watch is not a new law — it is the end of the war. Martial law was extended again on 13 July 2026 and now runs from 2 August 2026 for 90 days, so to about 31 October 2026. Several of today's permissions exist only while it lasts, and they die six months after it ends. A European-style replacement privacy law has been discussed for years and has still not been passed, so nothing about the current regime should be planned around its arrival.High confidence
Hardest industry wall: Government — Закон України "Про захист персональних даних", частина третя статті 4
Government — Закон України "Про захист інформації в інформаційно-комунікаційних системах"
Defence — Закон України "Про хмарні послуги"
Mapping and location — Кримінальний кодекс України, стаття 114-2

The eight framework questions answered for each selected country
Question	ThailandChecked 18 August 2026	UkraineChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Active	Depends on your industry Work: Medium Enforcement: Active
In one paragraph	Thailand does not make you keep personal data inside the country, but data cannot leave until you have picked and documented a legal route. The regulator never published a list of approved destination countries, so consent and written safeguards do all the work. A foreign company selling into Thailand needs a named representative living there. Getting it wrong can mean fines, double damages, and in the worst cases jail.	Ukraine still runs its 2010 privacy law, not a European-style one. Personal data may leave the country only to a country the law treats as safe — that means Europe and the 50-odd countries that signed a Council of Europe data treaty. The United States is not on that list. Fines are tiny, but the human rights Commissioner really does inspect, and misusing data can be a crime.
The catch	The permissive headline is about residency only. The burden is high and the pain is elsewhere: a person in Thailand who answers for you personally, parental consent for anyone under twenty in many cases, 90-day traffic logs that catch any business offering guest wi-fi, compensation owed even when you were not careless, and a technology-crime regime that forces banks and telecoms companies to hand customer data into a government-run exchange. Payments, government workloads and digital platforms each add their own regulator gate on top.	The general picture changes completely once government is involved. If a Ukrainian state body is the organisation deciding how personal data is used, only a Ukrainian state-owned or municipal company may process that data for it — a private or foreign supplier cannot. State systems, defence data and critical infrastructure also carry hard location rules, and several of the current permissions exist only because the country is under martial law.
Does this apply to me?	Yes. The privacy law reaches a company with no office in Thailand if it offers goods or services to people who are in Thailand, or if it tracks what those people do. Payment is irrelevant — a free service counts. There is no revenue or headcount floor to fall below. A foreign company caught this way must appoint, in writing, a representative who is physically in Thailand and who can be held answerable with no cap on liability.High confidence	Probably not, if you have nothing in Ukraine. The 2010 law simply says it covers the processing of personal data by automated means or in structured paper files. It contains no clause reaching foreign companies that only sell into Ukraine from abroad, and it does not make you appoint a local representative. There is no size or revenue threshold either — a corner shop and a bank are treated the same.Medium confidence
Can the data leave the country?	Yes, in most cases. Thailand does not make companies keep a copy of personal data inside the country. But data cannot simply leave: you must first have a legal route, and the regulator has never published a list of approved destination countries, so the 'this country is safe enough' route is unusable in practice. Everyone falls back on informed consent, contract necessity, approved group-wide rules, or their own written safeguards. Several industries add a second gate on top, described below.High confidence	Yes, but only to countries Ukraine already treats as safe. Those are the European Economic Area countries plus every country that has signed the Council of Europe's data protection treaty — roughly 55 states. The United States has signed neither, so routine transfers to American servers do not fit the safe-country route and need one of the narrow exceptions instead. Whole sectors then override this: government, defence and critical infrastructure are far tighter, and securities firms are unusually looser.High confidence
What do I have to do to send it abroad?	There is no permission slip to apply for and no banned-country list. You pick a route and document it before the data moves. The routes are: the destination is judged to have good enough protection; one of six statutory exceptions such as informed consent; group-wide rules certified by the regulator; or your own written safeguards that a person in Thailand could actually enforce. The 'good enough country' route is dead on arrival because the regulator has published no approved list, so in practice the safeguards route and consent do all the work.Medium confidence	There is no form to file and no government permission to obtain. You either send the data to a country the law already treats as safe, or you rely on one of five narrow exceptions. Those are: the person's clear consent, necessity for a contract made for that person's benefit, protecting someone's life, an important public interest or a legal claim, and the sender giving guarantees that private and family life will not be interfered with. That last one is a catch-all that a lot of Ukrainian practice leans on.High confidence
Who enforces this — and are they actually working?	The Office of the Personal Data Protection Committee, usually shortened to PDPC, sits under the Ministry of Digital Economy and Society. It is real and staffed: it has a serving Secretary-General, it runs walk-in complaint centres in five provinces and opened another in Ubon Ratchathani on 17 August 2026, and it is executing Cabinet-level instructions on data breaches. Complaints are decided by an Expert Committee that can order you to stop, order you to fix things, and impose fines itself. Other regulators run their own lanes: the cyber-security agency for critical infrastructure, the central bank for payments, and the electronic transactions agency for digital platforms.Medium confidence	The Ukrainian Parliament Commissioner for Human Rights — the national ombudsman — is the data protection regulator, and it is genuinely working. It publishes a fresh inspection programme every three months; the one for July to September 2026 went up on 2 July 2026. It also publishes what it found, including a run of checks on the national electronic health system. The catch is the money: the regulator cannot fine anyone itself, it writes up a case and sends it to a court, and the maximum penalty is about $800.High confidence
How long must I keep it, and when must I delete it?	Thailand pushes in both directions at once. The floor: anyone who provides a computer or internet service to other people must keep traffic logs for at least 90 days, and an official can order that stretched to as much as two years. The ceiling: the privacy law makes you build a system that actually deletes personal data once your stated retention period runs out or the data is no longer needed. When the two collide, the keep-it duty wins, because the delete duty has a written carve-out for complying with law and for defending legal claims.High confidence	The floor comes from tax law. Companies must keep primary accounting documents and financial statements for 1,825 days — five years. Papers needed for transfer pricing checks run to 2,555 days, which is seven years. Everything else the tax authority may ask for runs 1,095 days, three years. The ceiling comes from the privacy law: you must delete personal data when the agreed storage period runs out, or when your relationship with the person ends, unless another law tells you to keep it.High confidence
What happens when something goes wrong?	Count three clocks, not one. First: tell the privacy regulator about a personal data breach without delay and within 72 hours of becoming aware, unless the breach carries no risk to people; if the risk to people is high you must also tell the affected individuals, with advice on what to do, without delay. Second: if you run critical information infrastructure, a significant cyber threat must be reported to the national cyber-security agency and to your own sector regulator, and silence without good reason is itself an offence. Third: if you are a bank or a telecoms operator and you suspect technology crime, you must push customer account and transaction data into a shared government-run system immediately.High confidence	This is the biggest surprise in Ukrainian law: if you lose personal data, there is no duty to tell the regulator and no duty to tell the people affected. The 2010 privacy law simply has no breach reporting clause. The only mandatory clocks sit in the cyber security regime, and they only bite if you run a state system or a piece of critical information infrastructure. Even there the law does not set the hours — it leaves the deadline to an order of the cyber agency.Medium confidence
What's the trap?	Five things that are not in the brochure. Children: Thailand needs a parent's consent for a child aged ten or under, and for older teenagers too unless the act is one the law lets a minor do alone — and a person is a minor in Thailand until twenty. Jail is on the table for misusing sensitive data. You owe compensation even if you were not careless, and a court can add up to double on top. A foreign company must put a named human in Thailand with unlimited authority. And the 90-day log rule catches ordinary businesses that just offer guest wi-fi.High confidence	Five. (1) If a Ukrainian government body is the one deciding how personal data is used, only a Ukrainian state-owned or municipal company may handle that data for it — a private or foreign supplier is not allowed at all. (2) Misusing personal data is a crime, not just a fine, and repeat offences carry up to five years in prison. (3) The fines are aimed at named individuals and sole traders, not at companies. (4) Posting anything that shows where Ukrainian troops are carries five to eight years in prison. (5) Martial law lets the government limit the constitutional right to privacy that the whole system rests on.High confidence
What's about to change?	Nothing in the next twelve months looks like a new statute. What is moving is enforcement reach. The privacy regulator is opening walk-in centres in eight provinces during 2026 to cover all five regions, which means more complaints will actually get filed. The Cabinet decided on 11 August 2026 to require multi-factor login protection across government to stop leaked passwords turning into data breaches, and the ministry is pushing the same expectation across all twenty ministries. The bigger risk is not new law but switches the government already holds and can flip without warning.Medium confidence	The date to watch is not a new law — it is the end of the war. Martial law was extended again on 13 July 2026 and now runs from 2 August 2026 for 90 days, so to about 31 October 2026. Several of today's permissions exist only while it lasts, and they die six months after it ends. A European-style replacement privacy law has been discussed for years and has still not been passed, so nothing about the current regime should be planned around its arrival.High confidence
Hardest industry wall	None found.	Government — Закон України "Про захист персональних даних", частина третя статті 4 Government — Закон України "Про захист інформації в інформаційно-комунікаційних системах" Defence — Закон України "Про хмарні послуги" Mapping and location — Кримінальний кодекс України, стаття 114-2