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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

SlovakiaChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: Slovakia 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 areas break that rule. Online gambling servers must sit on Slovak soil. The most sensitive government data must stay in a Slovak data centre. And anyone who takes aerial survey pictures of Slovakia must hand a copy to a defence ministry archive.
The catch: The easy answer stops being true in three places. First, online gambling: the operator's server must be physically in Slovakia, with no European Economic Area alternative. Second, government cloud: a public body handling the top security category of data may only use a service that stores and processes it inside Slovakia, in a data centre within reach of the Slovak state. Third, mapping: primary aerial survey imagery and published maps must be deposited with Slovak state archives, including one run by the Ministry of Defence. Banking, payments, insurance, securities, health and telecoms have no storage-location rule that we could find.
Does this apply to me?: Yes. A company with no office in Slovakia is still caught if it offers goods or services to people in Slovakia, or watches what they do online. There is no minimum size, headcount or revenue below which you are safe. If you have no office anywhere in the European Union, you must name a written representative inside the Union, and you can put that person in any member state where your customers are — it does not have to be Slovakia.High confidence
Can the data leave the country?: In general, yes — with the standard European paperwork. Nothing in Slovak law says personal data must be kept in Slovakia, and the law says so almost in as many words: it applies to a Slovak company whether it processes data inside or outside the country. But three specific activities do force data to stay. Online gambling operators must put their server in Slovakia. The top security tier of government data must stay in a Slovak data centre. And aerial survey imagery of Slovakia must be handed to a state archive.High confidence
What do I have to do to send it abroad?: Slovakia uses the European model, and it is an allowlist. Data may go to a country the European Commission has approved, or to anywhere else if you sign the Commission's standard contract, use approved group-wide rules, or fit one of a few narrow exceptions. The approved list is real and populated — it includes the United Kingdom, Switzerland, Japan, South Korea, Canada for commercial bodies, and the United States only for companies signed up to the transatlantic framework. Slovakia adds nothing of its own on top.High confidence
Who enforces this — and are they actually working?: The Office for Personal Data Protection of the Slovak Republic. It is real, staffed and busy. In 2025 it issued 542 final fines totalling about 468,000 euros (roughly $510,000) and actually collected about 411,000 euros of that — a very high number of fines but a very small average, about 860 euros each. It has around 60 staff and got 20 extra posts in 2025. Cybersecurity incidents go to a separate body, the National Security Authority.High confidence
How long must I keep it, and when must I delete it?: There is no single retention rule. The general privacy rule is to delete when you no longer need the data. Against that sit long minimum-keeping duties: ten years for accounts and financial statements, and up to one hundred years after death for entries in the national health registers. Telecom companies keep far less than most people assume — Slovakia scrapped blanket call-record retention after its Constitutional Court struck it down, so operators only retain what a court order covers.High confidence
What happens when something goes wrong?: There are two clocks and they are different. A personal data breach goes to the privacy authority within 72 hours of you becoming aware of it, and to the affected people without undue delay if the risk to them is high. A cybersecurity incident at a regulated organisation goes to the National Security Authority twice: a first warning within 24 hours, then a fuller report within 72 hours. If you are both, you file both, to two different bodies.High confidence
What's the trap?: Five things that are not in the summary. Public bodies can be fined the full amount, with no discount. Mishandling personal data you got through your job is a crime, not just a fine. The age of consent for online services is 16, not 13. The rule on dead people's data changed today. And the gambling server rule has no European workaround.High confidence
What's about to change?: The whole national privacy law is being replaced by two new laws — one general, one for police and courts — but they are still bills and have no legal effect. Act 18/2018 was amended today, 18 August 2026, mostly to remove dead people from its scope. Public bodies face a bigger data-registration duty from 1 January 2027, and all cloud switching and data export fees across Europe must drop to zero by 12 January 2027.High confidence
Hardest industry wall: Online gaming — Zákon č. 30/2019 Z. z. o hazardných hrách a o zmene a doplnení niektorých zákonov, § 14 ods. 21 a 22
Government — Metodické usmernenie č. 020775/2025/oSBATA z 11. 4. 2025 pre proces zaradenia cloudovej služby do katalógu vládnych cloudových služieb, vydané podľa § 24a zákona č. 95/2019 Z. z.
Mapping and location — Zákon Národnej rady Slovenskej republiky č. 215/1995 Z. z. o geodézii a kartografii

The eight framework questions answered for each selected country
Question	UkraineChecked 18 August 2026	SlovakiaChecked 18 August 2026
The three ratings	Depends on your industry Work: Medium Enforcement: Active	Depends on your industry Work: High Enforcement: 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.	Slovakia 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 areas break that rule. Online gambling servers must sit on Slovak soil. The most sensitive government data must stay in a Slovak data centre. And anyone who takes aerial survey pictures of Slovakia must hand a copy to a defence ministry archive.
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 easy answer stops being true in three places. First, online gambling: the operator's server must be physically in Slovakia, with no European Economic Area alternative. Second, government cloud: a public body handling the top security category of data may only use a service that stores and processes it inside Slovakia, in a data centre within reach of the Slovak state. Third, mapping: primary aerial survey imagery and published maps must be deposited with Slovak state archives, including one run by the Ministry of Defence. Banking, payments, insurance, securities, health and telecoms have no storage-location rule that we could find.
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 Slovakia is still caught if it offers goods or services to people in Slovakia, or watches what they do online. There is no minimum size, headcount or revenue below which you are safe. If you have no office anywhere in the European Union, you must name a written representative inside the Union, and you can put that person in any member state where your customers are — it does not have to be Slovakia.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	In general, yes — with the standard European paperwork. Nothing in Slovak law says personal data must be kept in Slovakia, and the law says so almost in as many words: it applies to a Slovak company whether it processes data inside or outside the country. But three specific activities do force data to stay. Online gambling operators must put their server in Slovakia. The top security tier of government data must stay in a Slovak data centre. And aerial survey imagery of Slovakia must be handed to a state archive.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	Slovakia uses the European model, and it is an allowlist. Data may go to a country the European Commission has approved, or to anywhere else if you sign the Commission's standard contract, use approved group-wide rules, or fit one of a few narrow exceptions. The approved list is real and populated — it includes the United Kingdom, Switzerland, Japan, South Korea, Canada for commercial bodies, and the United States only for companies signed up to the transatlantic framework. Slovakia adds nothing of its own on top.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 Office for Personal Data Protection of the Slovak Republic. It is real, staffed and busy. In 2025 it issued 542 final fines totalling about 468,000 euros (roughly $510,000) and actually collected about 411,000 euros of that — a very high number of fines but a very small average, about 860 euros each. It has around 60 staff and got 20 extra posts in 2025. Cybersecurity incidents go to a separate body, the National Security Authority.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	There is no single retention rule. The general privacy rule is to delete when you no longer need the data. Against that sit long minimum-keeping duties: ten years for accounts and financial statements, and up to one hundred years after death for entries in the national health registers. Telecom companies keep far less than most people assume — Slovakia scrapped blanket call-record retention after its Constitutional Court struck it down, so operators only retain what a court order covers.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	There are two clocks and they are different. A personal data breach goes to the privacy authority within 72 hours of you becoming aware of it, and to the affected people without undue delay if the risk to them is high. A cybersecurity incident at a regulated organisation goes to the National Security Authority twice: a first warning within 24 hours, then a fuller report within 72 hours. If you are both, you file both, to two different bodies.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 are not in the summary. Public bodies can be fined the full amount, with no discount. Mishandling personal data you got through your job is a crime, not just a fine. The age of consent for online services is 16, not 13. The rule on dead people's data changed today. And the gambling server rule has no European workaround.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 whole national privacy law is being replaced by two new laws — one general, one for police and courts — but they are still bills and have no legal effect. Act 18/2018 was amended today, 18 August 2026, mostly to remove dead people from its scope. Public bodies face a bigger data-registration duty from 1 January 2027, and all cloud switching and data export fees across Europe must drop to zero by 12 January 2027.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	Online gaming — Zákon č. 30/2019 Z. z. o hazardných hrách a o zmene a doplnení niektorých zákonov, § 14 ods. 21 a 22 Government — Metodické usmernenie č. 020775/2025/oSBATA z 11. 4. 2025 pre proces zaradenia cloudovej služby do katalógu vládnych cloudových služieb, vydané podľa § 24a zákona č. 95/2019 Z. z. Mapping and location — Zákon Národnej rady Slovenskej republiky č. 215/1995 Z. z. o geodézii a kartografii