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Two or three countries, side by side, one row per question. Pick up to 3.
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»
GermanyChecked 18 August 2026
Yes, with paperworkWork: HighEnforcement: Active
- In one paragraph
- Contrary to widespread belief, neither Europe nor Germany requires personal data to be stored in Europe. What the law requires is a valid legal instrument before data leaves — an official decision that the destination is safe enough, or a standard contract, plus a documented risk assessment. Germany then adds its own layer on top, and one genuine hard wall: health and social data may only be processed in the cloud within Europe, by a provider holding a specific German security certificate.
- The catch
- 'Germany doesn't require local storage' is true right up until you sell to a hospital, a health insurer, a doctor, a lawyer or a tax adviser. In health and social care it is simply false, and for the professional-secrecy trades a standard data processing agreement is not enough and getting it wrong is a criminal matter.
- Does this apply to me?
- Yes, it reaches you with no office in Germany. Europe's privacy law applies to any organisation anywhere that offers goods or services to people in Europe or monitors their behaviour. If you have no European establishment you must also appoint a representative inside Europe.High confidence
- Can the data leave the country?
- Yes — with paperwork. This is the single most misunderstood point in the field. European law does not say where data must sit; it says what you must have in place before it leaves Europe. Storage location is a risk factor in that assessment, never a prohibition. For non-personal data, Europe goes further and actually forbids member states from imposing storage-location rules.High confidence
- What do I have to do to send it abroad?
- One of three routes. Best case, the destination is on Europe's official 'adequate' list and you need nothing extra — currently 17 entries including the UK, Japan, South Korea, Switzerland, Canada for commercial bodies, Brazil since January 2026, and the United States but only for companies self-certified under the EU-US Data Privacy Framework. Otherwise you sign Europe's standard contract clauses, or get group-wide internal rules approved. In either of those two cases you must also document an assessment of whether the destination country's surveillance laws undermine the protection.High confidence
- Who enforces this — and are they actually working?
- Eighteen separate authorities, and for a private company it is almost never the federal one. Each of the 16 states has its own regulator, and you answer to the one where your German office is. The federal regulator handles government bodies plus telecoms and postal operators. Bavaria splits it further, with different bodies for private and public sector. If you operate across Europe, a separate rule lets you deal mainly with the regulator where your main European establishment sits.High confidence
- How long must I keep it, and when must I delete it?
- Business records have a floor: accounting vouchers must be kept 8 years (cut from 10 with effect from 2025, and from 2026 for banks and insurers), the annual accounts and trading books still 10 years, and business correspondence 6 years. Privacy law pushes the other way — don't keep personal data longer than you need it. Where the two collide, German law has an elegant answer: you restrict processing of the data instead of deleting it.High confidence
- What happens when something goes wrong?
- 72 hours to tell your state regulator about a personal data breach, and without undue delay to tell affected people where the risk to them is high. Separately, since December 2025 Germany's cybersecurity law adds its own clocks for around 29,500 in-scope companies: a first warning within 24 hours, an update at 72 hours, and a full report within a month. Financial firms follow a separate European regime instead.High confidence
- What's the trap?
- Four. (1) Health and social data really does have to stay in Europe, with a specific German security certificate — the general 'no localisation' answer is wrong here. (2) For doctors, lawyers, tax advisers and notaries, a standard data processing agreement is NOT enough: you need explicit secrecy undertakings flowed down to every subcontractor, and breach is a criminal offence, not a fine. (3) Germany still requires a data protection officer at just 20 employees involved in data processing — far stricter than European law, and still in force despite a government promise to scrap it by the end of 2026. (4) The German rule people cite for employee data was effectively struck down by Europe's top court in 2023 but never removed from the statute book, so citing it as your legal basis is a mistake.High confidence
- What's about to change?
- Two hard dates and one live risk. From 12 January 2027 every cloud provider must drop switching and data egress fees to zero — renegotiate contracts now. By 31 December 2026 Germany's banking IT rulebook is fully withdrawn in favour of the European financial regime. The live risk is the US arrangement: Europe's data protection board formally asked the Commission on 31 July 2026 to review whether it is still valid, and a separate court appeal is pending. If it falls, thousands of transfers move to standard contracts overnight.High confidence
- Hardest industry wall
- Health and social care — § 393 SGB V — Cloud-Einsatz im Gesundheitswesen
- Telecoms — §§ 175–181 TKG — Vorratsdatenspeicherung