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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.

UzbekistanChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Waking up

In one paragraph: Uzbekistan used to say that data about its citizens had to sit on machines inside the country. In March 2026 it dropped that blanket rule. Most personal data may now be stored abroad if the destination country is on a new government approved list, or you use an approved contract, or you meet international standards. Three kinds of data still cannot leave at all.
The catch: The relaxed headline stops at three walls. Face and fingerprint data, genetic data, and data about customers of telephone and internet companies must be kept inside Uzbekistan. Banks face a separate rule that bans handing the running of their systems to an outside supplier, which blocks most managed cloud arrangements. Detailed maps are handled under state-secrecy rules.
Does this apply to me?: The law is written to cover the handling of personal data whatever tools are used, and it was aimed at foreign online platforms when the storage rules were first tightened in 2021. It does not set a size or revenue threshold, so a small foreign company is treated the same as a large one. We found no clear wording that forces a foreign company to appoint a representative living in Uzbekistan, and no explicit sentence saying the law follows the data outside the country.Medium confidence
Can the data leave the country?: Mostly yes, but only if you can point to one of three permissions. Face and fingerprint data, genetic data, and data about customers of telephone and internet companies must stay in Uzbekistan. Everything else may be stored and processed abroad if the destination country is on the government's approved list, or you sign an approved standard contract or use approved group rules, or you follow recognised international data standards.Medium confidence
What do I have to do to send it abroad?: The model is an approved list. Before ordinary personal data leaves the country you need one of three things: the destination is on the Cabinet of Ministers' list of countries with adequate protection, or you use the standard contract terms or group rules approved by the data authority, or you meet recognised international data standards. The country list was signed on 29 July 2026 and started on 3 August 2026, so it is brand new. We could not read which countries are on it, and no approved standard contract template appears to have been published yet.Medium confidence
Who enforces this — and are they actually working?: The data regulator is the State Centre for Personalization, which sits under the Cabinet of Ministers. It keeps the national register of personal data databases and can issue orders that companies and individuals must obey. It is a working government body and the registration service has run since 2020, but we found no published fines or decisions, so treat enforcement as waking up rather than active. Cyber incidents are handled by a different body, the State Security Service, and banks answer separately to the Central Bank.Medium confidence
How long must I keep it, and when must I delete it?: The ceiling is clear: personal data must be destroyed once the purpose is achieved, once consent is withdrawn, once the agreed period ends, or when a court orders it. The floor is thinner. Organisations covered by the cybersecurity law must keep backup copies covering at least the last three months. We did not verify the general tax and accounting minimum keeping periods during this run, so plan on the usual company record rules as well.Medium confidence
What happens when something goes wrong?: There are two clocks and they are not the same. The privacy law itself contains no duty to report a data breach to the regulator or to the people affected — we checked the text on 18 August 2026 and found none. The cybersecurity law is where reporting lives: organisations covered by it must tell the State Security Service about cyber incidents. Banks also report to the Central Bank under its security rules. We could not confirm a firm deadline in hours for any of these.Medium confidence
What's the trap?: First, every database of personal data has to be entered in a national register — it is a notification, it is free and it takes five working days, but skipping it is still a breach. Second, breaking the personal data rules can be a crime, not just a fine, so a named person can be prosecuted. Third, the face and fingerprint wall catches ordinary products like fingerprint logins and identity checks, not just spy technology. Fourth, banks are banned from handing the running of their technology and security systems to an outside supplier, which rules out most managed cloud and outsourced security operations. Fifth, the standard contract route for sending data abroad exists on paper but no approved template appears to have been published.Medium confidence
What's about to change?: The big change already happened in March 2026 and the follow-up is still landing. The approved country list started on 3 August 2026 and can be widened or cut by the Cabinet of Ministers at any time. The approved standard contract for sending data abroad is still missing, so watch for it. A new Tashkent International Financial Centre opened its legal regime on 25 July 2026 and its law also touched the privacy law, which may create a separate rulebook inside the centre. A national cybersecurity strategy was signed in March 2026.Medium confidence
Hardest industry wall: All industries — Закон «О персональных данных», статья 27-1, часть 2
Telecoms — Закон «О персональных данных», статья 27-1, часть 2 (данные пользователей услуг операторов телекоммуникаций)
Finance — Кредит бюроларининг ахборот хавфсизлиги ва киберхавфсизлигига доир минимал талаблар тўғрисидаги низом
Mapping and location — Положение о порядке установления ограничительных грифов картографических и геодезических материалов (данных)
Government — О мерах по организации деятельности Центра обработки данных системы «Электронное правительство»

The eight framework questions answered for each selected country
Question	ThailandChecked 18 August 2026	UzbekistanChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Active	Yes, with paperwork Work: High Enforcement: Waking up
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.	Uzbekistan used to say that data about its citizens had to sit on machines inside the country. In March 2026 it dropped that blanket rule. Most personal data may now be stored abroad if the destination country is on a new government approved list, or you use an approved contract, or you meet international standards. Three kinds of data still cannot leave at all.
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 relaxed headline stops at three walls. Face and fingerprint data, genetic data, and data about customers of telephone and internet companies must be kept inside Uzbekistan. Banks face a separate rule that bans handing the running of their systems to an outside supplier, which blocks most managed cloud arrangements. Detailed maps are handled under state-secrecy rules.
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	The law is written to cover the handling of personal data whatever tools are used, and it was aimed at foreign online platforms when the storage rules were first tightened in 2021. It does not set a size or revenue threshold, so a small foreign company is treated the same as a large one. We found no clear wording that forces a foreign company to appoint a representative living in Uzbekistan, and no explicit sentence saying the law follows the data outside the country.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	Mostly yes, but only if you can point to one of three permissions. Face and fingerprint data, genetic data, and data about customers of telephone and internet companies must stay in Uzbekistan. Everything else may be stored and processed abroad if the destination country is on the government's approved list, or you sign an approved standard contract or use approved group rules, or you follow recognised international data standards.Medium 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	The model is an approved list. Before ordinary personal data leaves the country you need one of three things: the destination is on the Cabinet of Ministers' list of countries with adequate protection, or you use the standard contract terms or group rules approved by the data authority, or you meet recognised international data standards. The country list was signed on 29 July 2026 and started on 3 August 2026, so it is brand new. We could not read which countries are on it, and no approved standard contract template appears to have been published yet.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	The data regulator is the State Centre for Personalization, which sits under the Cabinet of Ministers. It keeps the national register of personal data databases and can issue orders that companies and individuals must obey. It is a working government body and the registration service has run since 2020, but we found no published fines or decisions, so treat enforcement as waking up rather than active. Cyber incidents are handled by a different body, the State Security Service, and banks answer separately to the Central Bank.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	The ceiling is clear: personal data must be destroyed once the purpose is achieved, once consent is withdrawn, once the agreed period ends, or when a court orders it. The floor is thinner. Organisations covered by the cybersecurity law must keep backup copies covering at least the last three months. We did not verify the general tax and accounting minimum keeping periods during this run, so plan on the usual company record rules as well.Medium 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	There are two clocks and they are not the same. The privacy law itself contains no duty to report a data breach to the regulator or to the people affected — we checked the text on 18 August 2026 and found none. The cybersecurity law is where reporting lives: organisations covered by it must tell the State Security Service about cyber incidents. Banks also report to the Central Bank under its security rules. We could not confirm a firm deadline in hours for any of these.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	First, every database of personal data has to be entered in a national register — it is a notification, it is free and it takes five working days, but skipping it is still a breach. Second, breaking the personal data rules can be a crime, not just a fine, so a named person can be prosecuted. Third, the face and fingerprint wall catches ordinary products like fingerprint logins and identity checks, not just spy technology. Fourth, banks are banned from handing the running of their technology and security systems to an outside supplier, which rules out most managed cloud and outsourced security operations. Fifth, the standard contract route for sending data abroad exists on paper but no approved template appears to have been published.Medium 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 big change already happened in March 2026 and the follow-up is still landing. The approved country list started on 3 August 2026 and can be widened or cut by the Cabinet of Ministers at any time. The approved standard contract for sending data abroad is still missing, so watch for it. A new Tashkent International Financial Centre opened its legal regime on 25 July 2026 and its law also touched the privacy law, which may create a separate rulebook inside the centre. A national cybersecurity strategy was signed in March 2026.Medium confidence
Hardest industry wall	None found.	All industries — Закон «О персональных данных», статья 27-1, часть 2 Telecoms — Закон «О персональных данных», статья 27-1, часть 2 (данные пользователей услуг операторов телекоммуникаций) Finance — Кредит бюроларининг ахборот хавфсизлиги ва киберхавфсизлигига доир минимал талаблар тўғрисидаги низом Mapping and location — Положение о порядке установления ограничительных грифов картографических и геодезических материалов (данных) Government — О мерах по организации деятельности Центра обработки данных системы «Электронное правительство»