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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

SpainChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Aggressive

In one paragraph: Spain follows the normal European rule: personal data may leave the country once you have the right paperwork in place. But four named categories of data held by the Spanish state must physically stay inside the European Union, and may only travel further to a country Europe has officially approved. Spain's privacy regulator is one of the busiest in the world.
The catch: The relaxed headline stops being true the moment you touch the electoral roll, town-hall population registers, Spanish tax records or data about users of the Spanish national health service. For those four things a standard European transfer contract is not enough and never will be — the law allows only officially approved destinations. Online gambling, telecoms and any system sold to the Spanish public sector carry their own separate rules.
Does this apply to me?: Yes. A company with no office in Spain is still caught if it offers goods or services to people in Spain or watches what they do online. There is no size or revenue threshold to hide under. If you have no base anywhere in Europe you must appoint a written representative inside Europe, and Spain's regulator will happily deal with that representative instead of you.High confidence
Can the data leave the country?: For most businesses, yes, with paperwork — the ordinary European rules apply and nothing in Spanish law says data must sit on Spanish soil. The exception is sharp. If the data is the electoral roll, a town-hall population register, Spanish tax records, or information about users of the Spanish national health service, the computers holding it must be inside the European Union, and that data may only go outside Europe to a country Europe has officially approved. A standard European transfer contract does not work for those four things.High confidence
What do I have to do to send it abroad?: The model is an approved-list one, run at European level, not by Spain. You may send data outside Europe if the destination country is on Europe's approved list, or if you sign Europe's standard contract, or if your corporate group has approved internal rules. The list is real and populated. Spain adds one twist: if you want to use a home-made contract instead of the standard one, you must get written permission from the Spanish regulator first.High confidence
Who enforces this — and are they actually working?: The Spanish Data Protection Agency, and it is very much awake. Its public decision database held 46,925 decisions when we checked on 18 August 2026, with rulings signed as recently as 12 August 2026. Three regional authorities also enforce, covering public bodies in Catalonia, the Basque Country and Andalusia. Spain's artificial intelligence supervisor is now operating too and met the privacy agency in July 2026 to divide up the work.High confidence
How long must I keep it, and when must I delete it?: Both directions, and they collide. The longest floor is money laundering records: ten years, and the same law then orders you to destroy them. Business books run six years, clinical records at least five years from the end of each course of treatment, phone and internet connection records twelve months, and the taxman can come back four years. In the other direction Spain does something unusual: when someone asks you to delete their data you must not actually delete it, you must lock it away.High confidence
What happens when something goes wrong?: Count three clocks, not one. Everyone has 72 hours to tell the privacy regulator about a personal data breach. Phone and internet providers have only 24 hours under a separate European rule. And if you run something the state treats as an essential service, the cyber clock says report immediately, then send an update within 24 to 48 hours if the incident is critical, or 72 hours if it is very serious, with a final report 20 or 40 days later.High confidence
What's the trap?: Five things that ruin weekends. One: a child can consent at fourteen in Spain, not sixteen, so your global age gate is probably wrong here. Two: 'delete my data' legally means 'lock my data away', so a hard-delete pipeline breaks the law. Three: Spain forces far more organisations to appoint a data protection officer than Europe does, including every school, university, bank, insurer, energy supplier and online gambling operator. Four: misusing someone's personal records is a crime punishable by prison, and companies themselves can be prosecuted. Five: telecoms operators can be ordered to hand over the encryption method they use.High confidence
What's about to change?: The biggest thing is what has not happened. Spain still has not passed the law that brings Europe's new cybersecurity rules into Spanish law, so the old 2018 regime is still what binds — expect that to change and to widen sharply who must report incidents. From 12 January 2027 no cloud provider may charge you to leave or to pull your data out. Watch three switches the government can flip with no consultation: taking over telecoms networks, ordering gambling systems into Spain, and demanding an operator's encryption method.Medium confidence
Hardest industry wall: None found.

The eight framework questions answered for each selected country
Question	UkraineChecked 18 August 2026	SpainChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Depends on your industry Work: High Enforcement: Aggressive
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.	Spain follows the normal European rule: personal data may leave the country once you have the right paperwork in place. But four named categories of data held by the Spanish state must physically stay inside the European Union, and may only travel further to a country Europe has officially approved. Spain's privacy regulator is one of the busiest in the world.
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.	The relaxed headline stops being true the moment you touch the electoral roll, town-hall population registers, Spanish tax records or data about users of the Spanish national health service. For those four things a standard European transfer contract is not enough and never will be — the law allows only officially approved destinations. Online gambling, telecoms and any system sold to the Spanish public sector carry their own separate rules.
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	Yes. A company with no office in Spain is still caught if it offers goods or services to people in Spain or watches what they do online. There is no size or revenue threshold to hide under. If you have no base anywhere in Europe you must appoint a written representative inside Europe, and Spain's regulator will happily deal with that representative instead of you.High 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	For most businesses, yes, with paperwork — the ordinary European rules apply and nothing in Spanish law says data must sit on Spanish soil. The exception is sharp. If the data is the electoral roll, a town-hall population register, Spanish tax records, or information about users of the Spanish national health service, the computers holding it must be inside the European Union, and that data may only go outside Europe to a country Europe has officially approved. A standard European transfer contract does not work for those four things.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	The model is an approved-list one, run at European level, not by Spain. You may send data outside Europe if the destination country is on Europe's approved list, or if you sign Europe's standard contract, or if your corporate group has approved internal rules. The list is real and populated. Spain adds one twist: if you want to use a home-made contract instead of the standard one, you must get written permission from the Spanish regulator first.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	The Spanish Data Protection Agency, and it is very much awake. Its public decision database held 46,925 decisions when we checked on 18 August 2026, with rulings signed as recently as 12 August 2026. Three regional authorities also enforce, covering public bodies in Catalonia, the Basque Country and Andalusia. Spain's artificial intelligence supervisor is now operating too and met the privacy agency in July 2026 to divide up the work.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	Both directions, and they collide. The longest floor is money laundering records: ten years, and the same law then orders you to destroy them. Business books run six years, clinical records at least five years from the end of each course of treatment, phone and internet connection records twelve months, and the taxman can come back four years. In the other direction Spain does something unusual: when someone asks you to delete their data you must not actually delete it, you must lock it away.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	Count three clocks, not one. Everyone has 72 hours to tell the privacy regulator about a personal data breach. Phone and internet providers have only 24 hours under a separate European rule. And if you run something the state treats as an essential service, the cyber clock says report immediately, then send an update within 24 to 48 hours if the incident is critical, or 72 hours if it is very serious, with a final report 20 or 40 days later.High 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	Five things that ruin weekends. One: a child can consent at fourteen in Spain, not sixteen, so your global age gate is probably wrong here. Two: 'delete my data' legally means 'lock my data away', so a hard-delete pipeline breaks the law. Three: Spain forces far more organisations to appoint a data protection officer than Europe does, including every school, university, bank, insurer, energy supplier and online gambling operator. Four: misusing someone's personal records is a crime punishable by prison, and companies themselves can be prosecuted. Five: telecoms operators can be ordered to hand over the encryption method they use.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	The biggest thing is what has not happened. Spain still has not passed the law that brings Europe's new cybersecurity rules into Spanish law, so the old 2018 regime is still what binds — expect that to change and to widen sharply who must report incidents. From 12 January 2027 no cloud provider may charge you to leave or to pull your data out. Watch three switches the government can flip with no consultation: taking over telecoms networks, ordering gambling systems into Spain, and demanding an operator's encryption method.Medium 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	None found.