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

Countries

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»

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	UzbekistanChecked 18 August 2026	SpainChecked 18 August 2026
The three ratings	Yes, with paperwork Work: High Enforcement: Waking up	Depends on your industry Work: High Enforcement: Aggressive
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.	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 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.	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?	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	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?	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	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. 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	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 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	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 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	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?	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	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?	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	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 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	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	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»	None found.