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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»
FranceChecked 18 August 2026
Depends on your industryWork: HighEnforcement: Aggressive
- In one paragraph
- France follows the European rule: data may leave, but only once the right paperwork is in place. France then adds hard walls of its own. Health records must be stored inside Europe. Online gambling records must sit on a machine in mainland France. From 1 September 2026 the invoicing platform every French business must use has to run entirely from inside Europe.
- The catch
- "France has no local storage rule" is true for an ordinary business and false the moment you touch health data, online gambling, electronic invoicing or a government contract involving sensitive state data. In those four areas France is among the strictest countries in Europe. Since March 2026 the health rule sits in a decree, not just a certification standard, so it now binds the customer as well as the supplier.
- Does this apply to me?
- Yes. France reaches a company with no office in the country. European law already applies to anyone offering goods or services to people in Europe. On top of that, France's own privacy law says its national rules apply as soon as the person concerned lives in France, even when the company is based somewhere else. There is no size or revenue threshold that lets you escape.High confidence
- Can the data leave the country?
- For an ordinary business, yes, with paperwork: the European transfer rules apply and nothing extra is added. But four French sectors override that. Health records must be stored inside Europe and nowhere else. Online gambling records must be archived in real time on hardware in mainland France. Electronic invoicing platforms must run their whole system from inside Europe. And sensitive state data must sit on a cloud that the French cyber agency has certified as beyond the reach of foreign authorities.High confidence
- What do I have to do to send it abroad?
- The model is an approved-list one, run from Brussels rather than Paris. Data may go to a country the European Commission has formally approved, or anywhere else if you sign the official standard contract and write down why you think the data will still be safe. The list of approved countries is full, not empty: it includes the United Kingdom, Japan, South Korea, Canada, Switzerland, Brazil and about a dozen others, plus American companies that have signed up to the transatlantic framework. France adds no separate national approval step.High confidence
- Who enforces this — and are they actually working?
- The privacy regulator is the CNIL, and it is one of the busiest in Europe. In 2025 alone it issued 83 penalties totalling about 487 million euros (roughly 530 million dollars), plus 143 formal warnings. It is still fining in 2026: 5 million euros against the national employment agency in January and 5 million against a health data company in May. Separate regulators run the sector walls, and all of them are staffed and working.High confidence
- How long must I keep it, and when must I delete it?
- There is a floor and a ceiling and they pull in opposite directions. You must keep accounting books and supporting documents for ten years, tax records for six, employment contracts and pay records for five, and telephone and internet subscriber identity data for five. In the other direction, European law says you must delete personal data once you no longer need it. France resolves the clash the same way most of Europe does: the legal minimum wins, but only for the specific documents the law names, and only for as long as it names.High confidence
- What happens when something goes wrong?
- Count the clocks, because France has at least four and they run at different speeds. Every organisation has 72 hours to tell the CNIL about a personal data breach. Telephone and internet providers have only 24 hours. Hospitals and clinics must report a serious computer security incident to their regional health agency immediately. Banks, insurers and investment firms have their own European deadlines: an initial report within 4 hours of classifying a major incident and no later than 24 hours after they notice it.High confidence
- What's the trap?
- Five things that are not in the summary. (1) Breaking the privacy law in France is a crime, not just a fine: sending data out of Europe unlawfully carries up to five years in prison and a 300,000 euro fine (about 330,000 dollars), and it attaches to people, not only companies. (2) A child is anyone under 15 for consent, not 13 or 16. (3) A 2023 law setting a social media age of 15 is printed in the statute book but has never come into force and cannot be enforced. (4) Handing documents to a foreign court or regulator can itself be a criminal offence in France. (5) Cookies are policed separately from the rest of privacy law, so a foreign company cannot hide behind its lead European regulator.High confidence
- What's about to change?
- Four dates in the next twelve months. 1 September 2026: every French business must be able to send and receive invoices through an approved platform, and those platforms must run entirely from inside Europe. Around 27 September 2026: the second phase of the health data hosting decree starts. 21 October 2026: the order forcing telephone and internet companies to keep everyone's connection records for a year expires unless the Prime Minister renews it. 12 January 2027: cloud providers across Europe must drop switching and data export fees to zero.Medium confidence
- Hardest industry wall
- Health and social care — Decret n° 2026-209 du 24 mars 2026 portant modification de certaines dispositions du code de la sante publique relatives a l'hebergement de donnees de sante a caractere personnel
- Government — Decret n° 2026-272 du 14 avril 2026 relatif a la protection des donnees d'une sensibilite particuliere des administrations, operateurs et groupements d'interet public de l'Etat traitees par un service d'informatique en nuage fourni par un prestataire prive
- All industries — Immatriculation des plateformes agreees (ex plateformes de dematerialisation partenaires) - facturation electronique
- Online gaming — Article 31 de la loi n° 2010-476 du 12 mai 2010 relative a l'ouverture a la concurrence et a la regulation du secteur des jeux d'argent et de hasard en ligne