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Privacy by design

Personal control.
Local obligations.

Autonym is designed around specific permission, limited disclosure and a record the person controls. Those choices support important privacy principles across jurisdictions. Every deployment also needs the legal basis, safeguards and operating processes its laws require.

International privacy guide · Reviewed

How the design helps

The useful common ground is practical: make purposes clear, disclose only what is needed, keep the person’s choices effective and provide evidence of what happened. These are design contributions to compliance, alongside the obligations of the host and each recipient.

Design choiceWhat it supportsWhat still needs to be done
Specific permissionA named recipient, stated purpose, selected data and limited duration make access easier to understand and constrain. Read and contribution permissions are separate.Consent still needs the right notice, legal basis and any local formalities. A grant cannot authorise prohibited processing.
Less data disclosedDefined disclosure levels, restricted sensitive keys and short-lived responses limit what a compatible recipient receives.Coarse information and inferences can still be personal or sensitive data. Local classifications and necessity tests apply.
Visible access and correctionReceipts, provenance and correction rules support transparency and help trace where information came from and went.A read log is only part of a rights response. Corrections, objections and decision reviews need an operating process.
Withdrawal and deletion supportRevocation stops future reads through the provider. Purge notices and acknowledgements support follow-up with recipients.Revocation cannot retract a copy already disclosed. Backups, retention exceptions and actual deletion must be handled separately.
Portable recordsDefined export and import contracts support moving supported categories without carrying over live grants or credentials.Statutory portability has local conditions. Other people’s rights, secure delivery and fresh destination permissions still matter.

What a deployment must establish

Chapter A16: Privacy and legal mapping requires six groups of deployment evidence. These apply to providers and recipients claiming conformance, alongside the technical checks. Their implementation and operational evidence remain pending in the reference service.

  1. Establish the local legal basis

    Map applicable laws, actual controller and processor roles, notices, consent evidence and collection duties before processing. PRIVACY-01

  2. Apply local limits to sensitive data

    Assess what each value, inference and combination reveals. Keep unsupported categories and prohibited further uses disabled. PRIVACY-02

  3. Approve each international flow

    Cover hosting, backups, remote access, subprocessors and onward disclosure with the safeguards that the relevant law requires. PRIVACY-03

  4. Operate rights and deletion processes

    Track local deadlines, propagate corrections, bound retention, handle legal holds and reapply deletions after backup restoration. PRIVACY-04

  5. Respect advertising choices and children’s protections

    Honour applicable opt-outs and preference signals after grant issue. Keep affected features disabled without the required safeguards. PRIVACY-05

  6. Provide accountable operation

    Complete required assessments, contracts, registrations and permits; track approval validity, exercise incident response and support applicable decision-review rights. PRIVACY-06

Permission has limits

An adult choosing to share data does not make every use lawful. Some laws restrict particular sensitive-data processing even with consent. International access may require separate contracts or assessments. A later advertising opt-out may stop a use that an earlier grant permitted. Unsupported uses must stay disabled.

Autonym’s optional advertising design is off by default and limited to three explicitly selected ordinary preference keys. It excludes sensitive information, location and children’s records. Those restrictions reduce exposure, but do not settle the legal definitions of sale, sharing or targeted advertising. See the advertising rules.

Some safeguards require permission before processing

Certain sensitive-data uses need a regulator’s permit. Some jurisdictions distinguish approval to store data abroad from permission to transfer it, or impose local-storage requirements. A submitted application, personal consent or encrypted hosting cannot replace the applicable approval. The entries for Qatar, Oman, Rwanda, Zambia and other affected jurisdictions identify those checks. A16 requires granted permissions to remain valid and cover the actual activity.

Responsibility follows the actual activity

A host, person, contributor and recipient are protocol actors. Their legal roles depend on who decides why and how data is processed. Encryption, self-hosting and a person’s household use do not automatically exempt a commercial service. The EU Data Governance Act and India’s registered Consent Manager framework may also require an activity-specific assessment; providing a consent screen does not establish either status.

EDPB: controller and processor roles ; European Commission: data intermediation . India’s official rules are linked in its entry below.

The jurisdiction guide

68 entries cover the jurisdictions below, including the EU framework underlying EEA implementation and a separate US state overview. “In force” describes legislation, not Autonym’s compliance. Notes highlight relevant differences and are not complete accounts of each law. More than one regime can apply to the same processing.

Europe and nearby jurisdictions

Jurisdiction and main regulationHow Autonym can helpLocal notes and sources
European UnionGDPR, Regulation (EU) 2016/679; national supplementary laws and ePrivacy rulesIn forceSpecific grants, limited disclosure, correction, revocation and export support core privacy principles and individual rights.

Identify an Article 6 basis and, where needed, an Article 9 condition. Assess controller roles, notices, rights, security, impact assessments and Chapter V transfers. National rules still differ. An Autonym grant does not grant permission to use cookies or send marketing.

United KingdomUK GDPR, Data Protection Act 2018 and PECR, as amended by the Data (Use and Access) Act 2025In force; 2026 changes applyPurpose-specific permissions, withdrawal and an accessible record can support UK transparency and control.

Use the amended UK rules separately from EU GDPR. The complaints procedure requirement took effect on 19 June 2026: provide a clear route, acknowledge within 30 days and respond without undue delay. Review UK transfer safeguards, sensitive data conditions and PECR separately.

NorwayEU GDPR through the EEA, supplemented by Norwegian lawIn forceThe EU GDPR mapping provides the shared baseline for grants, minimisation and individual control.

GDPR has applied through the EEA since 20 July 2018. Check Norwegian supplementary and sector rules, supervisory procedures and the actual transfer route. EEA participation does not make every recipient outside the EEA an authorised destination.

IcelandEU GDPR through the EEA, supplemented by Icelandic lawIn forceThe EU GDPR mapping provides the shared baseline for grants, minimisation and individual control.

GDPR has applied through the EEA since 20 July 2018. Assess Icelandic supplementary and sector rules and local rights procedures. Hosting in Iceland does not resolve the legality of subsequent disclosures to overseas assistants.

LiechtensteinEU GDPR through the EEA, supplemented by Liechtenstein lawIn forceThe EU GDPR mapping provides the shared baseline for grants, minimisation and individual control.

GDPR has applied through the EEA since 20 July 2018. Apply the local supplementary rules and regulator procedures. A provider and its recipients still need the appropriate legal roles, agreements and transfer safeguards.

SwitzerlandRevised Federal Act on Data Protection (FADP), with implementing ordinancesIn force since 1 September 2023Limited disclosure and person-controlled permissions support proportionality and privacy by design.

The Swiss private-sector framework is not a copy of GDPR's six-basis model. Assess personality-rights protection, sensitive data, high-risk processing and transparency. Use the Swiss rules for overseas disclosures and any required contractual adaptations; EU paperwork alone is not a complete Swiss assessment.

JerseyData Protection (Jersey) Law 2018In forceNamed recipients and controlled disclosure support purpose limitation and accountability.

Use Jersey's lawful-processing and special-category conditions. Restricted transfers may require the EU standard contractual clauses together with the Jersey Addendum and a transfer assessment. Do not substitute UK or EU jurisdiction labels for the local analysis.

GuernseyData Protection (Bailiwick of Guernsey) Law 2017In force since 25 May 2018Grants, disclosure records and revocation support the law's individual-control principles.

Assess local registration and levy duties and the conditions for sensitive processing. For applicable overseas transfers, use the Guernsey transfer guidance, impact assessment and local SCC addendum. A technical recipient registration is not registration with the authority.

Isle of ManData Protection Act 2018, applied GDPR and GDPR and LED Implementing Regulations 2018In forceThe shared GDPR mechanisms are useful for an implementation subject to the applied GDPR.

Use the Manx application orders and implementing regulations, including local modifications and enforcement arrangements. UK DUAA amendments must not be assumed automatically to amend Manx law. Review recipient disclosures under the applied framework.

TurkeyPersonal Data Protection Law No. 6698 (KVKK), as amendedIn force; 2024 transfer reforms applySeparate purposes and controlled recipients can support lawful disclosure and withdrawal.

Apply the amended sensitive-data and overseas-transfer rules. Article 9 now includes mechanisms such as standard contracts and binding corporate rules. Complete the relevant local documentation and filing requirements; an Autonym grant or an EU SCC does not replace a KVKK transfer mechanism.

SerbiaLaw on Personal Data Protection, Official Gazette No. 87/2018In forcePurpose-specific access and auditable changes support the law's accountability structure.

Assess local legal grounds, sensitive-data conditions and international-transfer rules rather than treating Serbia as part of the EEA. Large-scale sensitive processing or systematic monitoring can trigger a data protection officer requirement. Determine the provider's and recipient's duties separately.

AlbaniaLaw No. 124/2024 on Personal Data ProtectionReplacement framework in forceThe newer GDPR-aligned framework is well matched to minimisation, purpose-specific permissions and rights support.

Use Law 124/2024 and its implementing measures, not only the older 2008 law. Verify local transfer decisions and any phased organisational requirements. Alignment with GDPR does not establish EU adequacy or certify an implementation.

MontenegroLaw on Personal Data Protection; replacement legislation under reviewReform status needs confirmationLimited collection, named recipients and an access history provide useful building blocks under the existing framework.

The government published a proposed replacement law and conclusions in September 2026. This review does not establish its enactment or commencement. Confirm the governing text, transfer approvals and registration requirements before deployment; do not describe a proposal as law already in force.

North MacedoniaLaw on Personal Data Protection, Official Gazette No. 42/2020, as amendedIn forceGrants, purpose limitation and rights support are compatible building blocks for the local framework.

Use the agency's current law and amendment register, including the 2021 amendments and subsequent applicable measures. Assess local overseas-transfer procedures, sensitive-data conditions and DPO duties. A GDPR-based implementation still needs local configuration.

Bosnia and HerzegovinaLaw on Protection of Personal Data, Official Gazette No. 12/2025Applies from 4 October 2025A more detailed rights and accountability framework reinforces the value of controlled disclosure and traceable access.

Use the 2025 replacement law and its transitional provisions. The agency confirms that application began on 4 October 2025. Check organisational transition duties and local implementing rules rather than continuing to rely solely on the older framework.

MoldovaLaw No. 195/2024 on Personal Data ProtectionIn force since 23 August 2026The new GDPR-aligned framework supports a mapping to grants, minimisation, accountability and rights.

Law 195/2024 is now the relevant general framework; it must not be presented as a future reform or replaced with the old Law 133/2011 in a current assessment. Complete the new local controller, rights, security and transfer analysis.

GeorgiaLaw of Georgia on Personal Data Protection, 2023, as amendedIn force; oversight changed in 2026Grants and traceable processing support consent, transparency and individual control.

Use the current consolidated law. Data-protection oversight transferred to the State Audit Office from 2 March 2026. Configure incident escalation, impact assessments and transfer safeguards against the current authority and law, not obsolete regulator details.

UkraineLaw No. 2297-VI on Personal Data Protection, as amendedIn force; broader reform remains a watch itemPurpose-specific sharing, correction and access records can support the existing rights framework.

The official register identifies Law 2297-VI as current. Assess sensitive processing, foreign disclosures and applicable sector or wartime measures. EU accession work is not itself enactment of a replacement GDPR-style law.

Asia and the Pacific

Jurisdiction and main regulationHow Autonym can helpLocal notes and sources
AustraliaPrivacy Act 1988 and Australian Privacy Principles (APPs), as amendedIn force; further change on 10 December 2026Limited collection, controlled disclosure and correction support APP-based privacy management.

Determine APP coverage, including relevant health-service and small-business exceptions. Assess sensitive-information consent, APP 8 overseas disclosure, APP 11 security/retention and breach reporting. Additional privacy-policy disclosure about certain automated decisions begins on 10 December 2026.

New ZealandPrivacy Act 2020, as amended by the Privacy Amendment Act 2025In force; IPP3A applies from 1 May 2026Contribution provenance and person review can support transparency when information comes from another service.

Provide indirect-collection notices where IPP3A requires them; a proposal waiting in Autonym is already collected information. Assess IPP12 for overseas disclosures, including its distinction from some agency processing arrangements. Health-sector codes may add duties.

ChinaPersonal Information Protection Law (PIPL), supported by cybersecurity and data-security legislationIn force; local deployment assessment essentialPurpose limits and low disclosure can reduce exposure, but cannot authorise an overseas recipient.

Assess separate consent and necessity for sensitive information, recipient notices, impact assessments and Articles 38-40 transfer/local-storage conditions. Apply current CAC thresholds and exemptions. Do not enable a cross-border flow until its actual route is authorised; not all personal information has a blanket localisation requirement.

JapanAct on the Protection of Personal Information (APPI), as amendedIn forceA specific recipient and purpose can support transparency and third-party disclosure decisions.

Check special-care-required information, acquisition consent and third-party provision separately. Overseas provision may need informed consent or an applicable equivalent-protection route and continuing safeguards. Read the current Japanese law and guidance; older English translations can lag amendments.

South KoreaPersonal Information Protection Act (PIPA), as amendedIn forceSeparated purposes, visible recipients and narrow permissions support meaningful choices.

Distinguish entrusted processing from provision to another controller. Review sensitive-data consent and the applicable overseas-transfer basis, required notice and recipient details. PIPC's 2025 enforcement illustrates that describing a recipient as a processor does not settle its real legal role.

IndiaDigital Personal Data Protection Act 2023 and DPDP Rules 2025; transitional IT-law requirementsPhased commencementClear purposes, separate choices and easy withdrawal fit the DPDP design.

Do not describe all DPDP duties as already operative. The 2025 rules phase commencement: consent-manager rules after one year and most substantive rules after eighteen months. Map the Act's separate commencement notification and existing IT/SPDI duties. Autonym is not automatically a registered Consent Manager; that is a regulated role.

SingaporePersonal Data Protection Act 2012 (PDPA), as amendedIn force; portability commencement separatePurpose and retention limits, access records and correction support the PDPA obligations.

Apply accountability, notification, consent or a valid exception, breach duties and comparable protection for overseas transfers. The PDPC page still describes the statutory portability obligation as taking effect when regulations are issued. Autonym can offer portability without claiming that right is already operative.

ThailandPersonal Data Protection Act B.E. 2562 (2019), with implementing rulesIn forcePurpose-specific permission and separate read/contribution flows support controlled processing.

Identify the ordinary legal basis and any section 26 sensitive-data condition. Assess sections 28-29 and implementing rules for overseas transfers, controller/processor agreements, rights handling and breach procedures. General consent must not be treated as every required sensitive-data or transfer consent.

MalaysiaPersonal Data Protection Act 2010, as amended by the Personal Data Protection (Amendment) Act 2024Amendments commenced in stages in 2025Structured permissions, export and access evidence support the revised accountability framework.

Assess commercial-transaction scope, sensitive information, processor security, DPO and breach duties, portability conditions and revised transfer rules. DPO requirements took effect on 1 June 2025. Use the current Commissioner guidance, not only the original 2010 provisions.

IndonesiaPersonal Data Protection Law No. 27 of 2022In force; implementation measures require reviewSpecific purpose, provenance and controlled disclosure support the law's processing principles.

Specific personal data includes health, biometrics, children's information and personal financial data. Assess impact assessments, DPO triggers, rights and cross-border conditions. Article 46 prescribes a 3 x 24-hour breach-notice period. Review implementing measures and relevant court decisions before deployment.

PhilippinesRepublic Act No. 10173, Data Privacy Act 2012, and implementing rulesIn forceNarrow grants and visible purposes support transparency, legitimate purpose and proportionality.

Sensitive and privileged information have separate processing conditions. A controller remains accountable for information transferred for processing, domestically or internationally. Apply contracts or comparable safeguards, registration where required, breach procedures and statutory rights; consent must remain withdrawable.

VietnamPersonal Data Protection Law No. 91/2025/QH15 and Decree No. 356/2025/ND-CPBoth effective 1 January 2026Purpose-specific permissions and controlled transfer records are useful inputs to a local compliance programme.

The assessment must use the new law and implementing decree, not Decree 13/2023 alone. Before enabling a recipient, verify consent, sensitive-data, processing-impact and cross-border dossier requirements, exemptions and applicable storage rules against the current Vietnamese text.

Hong KongPersonal Data (Privacy) Ordinance (PDPO), Cap. 486In forceData minimisation, restricted use and correction align with the six data protection principles.

Apply direct-marketing requirements separately. Overseas outsourcing still requires security and retention safeguards. PCPD material describes section 33's transfer restriction as uncommenced; this review does not establish a later commencement. Confirm that point before relying on it, and do not interpret it as permission for unrestricted exports.

TaiwanPersonal Data Protection Act (PDPA), with amendments and implementing rulesIn force; 2025 amendment commencement requires careSpecific purposes, correction and cessation of use support statutory control over personal information.

Article 6 restricts medical, genetic, sexual-life and other listed information; written consent is one conditional route. Apply indirect-collection notices and any sector transfer restrictions. The official register marks parts of the November 2025 amendments as awaiting commencement; do not treat every amended provision as operative.

Sri LankaPersonal Data Protection Act No. 9 of 2022, amended by Act No. 22 of 2025Phased commencement; key duties from 1 January 2027Grants, rights support and purpose limits are suitable design inputs for the amended framework.

The July 2026 commencement order sets 1 January 2027 for sections 2 and 3, Part I and Part III. This is not commencement of every provision, including all rights in Part II. Use the amended Act and check each applicable part, transfer instrument and regulator procedure before launch; the original March 2025 date was postponed.

The Americas

Jurisdiction and main regulationHow Autonym can helpLocal notes and sources
CanadaPIPEDA plus provincial laws, including Québec's private-sector Act as amended by Law 25 and Alberta/BC PIPAsOverlapping federal and provincial rulesMeaningful permission, limited purposes and correction support the shared principles; export supports Québec portability.

Map the activity and province. PIPEDA remains relevant to commercial interprovincial/international flows. Québec requires a privacy assessment before communicating information outside Québec; its portability provisions apply from 22 September 2024. Assess express consent for sensitive information, provincial health laws and accountable outsourcing separately.

United StatesFederal sector and consumer-protection laws, alongside state privacy lawsNo single general federal equivalent to GDPRNarrow access and auditable sharing help, but the relevant sector and state determine the obligations.

Assess FTC Act duties, HIPAA relationships, the FTC Health Breach Notification Rule, COPPA and relevant financial, education, biometric and state health laws. A direct-to-consumer health record is not automatically subject to HIPAA; absence of HIPAA coverage does not remove privacy obligations.

CaliforniaCCPA, as amended by the CPRA, and CPPA regulationsIn force; new rules have staged compliance datesAccess, correction, deletion support and narrow permissions help implement consumer choices.

Assess business coverage, service-provider contracts, sale/sharing and sensitive-information limits. Honour applicable opt-out preference signals; an ordinary grant must not silently override them. Risk-assessment requirements began in 2026, while the new automated-decision requirements begin in 2027 and audit deadlines are staged. A read log is not the full required assessment.

Other US statesState comprehensive consumer privacy laws and additional sector lawsState-by-state scope and effective datesCommon access, deletion, portability and purpose controls can share implementation, with local variations.

Review Virginia, Colorado, Connecticut, Texas, Oregon, Montana, Delaware, New Jersey, Maryland and Minnesota individually. Other enacted regimes include Utah, Iowa, Indiana, Tennessee, Nebraska, New Hampshire, Kentucky and Rhode Island. Coverage, exemptions, sensitive-data treatment, appeals and opt-out signals differ. The state notes below identify key differences; this is not an exhaustive US-law inventory.

BrazilLei Geral de Proteção de Dados (LGPD), Law No. 13,709/2018In forcePurpose-specific access, correction and portability support data-subject control.

Use the distinct sensitive-data grounds and assess data-subject rights and security duties. International transfers need an LGPD mechanism. ANPD Resolution 19/2024 establishes local transfer arrangements and standard clauses; do not assume an EU contract or protocol grant is enough.

MexicoFederal Law on Protection of Personal Data Held by Private Parties (LFPDPPP), new 2025 law as amendedReplacement law published 20 March 2025Specific permissions and an accessible record support notice and ARCO rights workflows.

Use the new private-sector law and current authority arrangements, not only the repealed 2010 text. Assess privacy notices, sensitive-data consent formalities, transfers and access, rectification, cancellation and opposition. The official consolidated text records a further amendment on 14 November 2025.

ArgentinaPersonal Data Protection Law No. 25,326 and implementing rulesIn force; sensitive-data use needs particular carePurpose limitation and correction are useful, but ordinary grant consent is not a universal sensitive-data permission.

Articles 7-8 impose specific restrictions on sensitive-data databases and health processing. Obtain a local assessment before enabling health, identity or other sensitive categories; do not assume an opt-in cures a prohibition. Assess AAIP transfer mechanisms separately. An Autonym account must not be treated as an automatic exemption.

UruguayPersonal Data Protection Law No. 18,331, as amendedIn forceSpecific purposes, consent evidence and correction support the local framework.

Review sensitive-data formalities, local registration, accountable processing and breach requirements. Article 23 restricts international transfers and provides specified exceptions and authorisation routes. A recipient's technical compatibility is not evidence of adequate legal protection.

ColombiaLaw 1581 of 2012 and implementing decreesIn forceSpecific prior permission and purpose-bound access support authorisation and transparency.

Explain the optional nature of sensitive-data answers and use a permitted sensitive-data condition. Distinguish controller-to-controller transfer from transmission to a processor and apply the relevant rules and contracts. Assess database-registration scope and overseas adequacy or exceptions; not every foreign disclosure follows the same route.

PeruPersonal Data Protection Law No. 29,733 and Supreme Decree No. 016-2024-JUSNew regulation effective 31 March 2025Narrow purposes, traceable collection and rights support fit the revised framework.

Use the replacement regulation. Assess local representation, data protection officer triggers, consent and sensitive-data formalities, transfers and registration. Covered security incidents can trigger a 48-hour notification requirement. Configure duties and deadlines locally, including any staged provisions.

ChileLaw No. 19,628; reforms under Law No. 21,719Existing law now; major reform on 1 December 2026Specific purposes, correction and export provide a useful basis for both present and upcoming requirements.

Apply the currently operative Law 19,628 until the reform's commencement. Prepare for the expanded rights, accountability, regulator and international-transfer regime from 1 December 2026. The official register explicitly separates the current and future consolidated texts.

EcuadorOrganic Law on Personal Data Protection and implementing rulesIn forcePurpose limits, correction and portability support the law's rights and accountability structure.

Sensitive categories expressly include gender identity and cultural identity, alongside other protected data. Classify context under local law, including what a value reveals indirectly. Assess local representation, DPO/impact duties where applicable and overseas-transfer mechanisms under current SPDP measures.

PanamaLaw No. 81 of 2019 and Executive Decree No. 285 of 2021Law effective 29 March 2021Consent evidence, purpose limits and export support the local principles and rights framework.

Assess the law together with the implementing decree, including sensitive information, controller/custodian responsibilities, overseas transfers and statutory rights. A general purpose statement or a purge acknowledgement is not the full notice, contractual or deletion process.

Costa RicaLaw No. 8968 on Protection of the Person in the Processing of Personal Data and implementing regulationsIn force; sensitive-data use needs particular careLimited purposes and access/correction controls are useful, subject to the law's category restrictions.

Article 9 restricts sensitive-data processing and enumerates exceptions. Do not assume ordinary explicit consent alone permits a general health or identity database. Obtain local confirmation of any exception and of the law's database scope; assess transfer consent and PRODHAB duties separately.

Middle East

Jurisdiction and main regulationHow Autonym can helpLocal notes and sources
IsraelProtection of Privacy Law 1981, as amended, and implementing regulationsAmendment 13 effective 14 August 2025Specific purposes, access evidence and correction support accountability and individual control.

Use Amendment 13, the security regulations and applicable overseas-transfer rules. Assess updated sensitive-information definitions, DPO triggers and database registration or notification duties. The regulator issued final DPO guidance in July 2026. An Autonym grant does not replace required organisational or database obligations.

United Arab EmiratesFederal Decree-Law No. 45 of 2021 on the Protection of Personal DataFederal law effective 2 January 2022; implementing position needs confirmationPurpose limits, withdrawal and correction provide useful design support within the applicable regime.

First distinguish federal coverage from DIFC/ADGM and excluded government, health and banking data governed by other rules. Health-sector legislation can apply in free zones too. Verify executive regulations and any associated compliance timetable before launch; this review does not establish their current issuance. Assess health-data location rules and permitted cross-border routes separately.

Dubai International Financial CentreDIFC Data Protection Law No. 5 of 2020, as amended, and Data Protection RegulationsIn force; 2025 amendments and a 2026 consultationPurpose-bound permissions and provenance support transparency and accountable processing.

Use the DIFC regime independently from UAE federal law. Review special categories, high-risk assessments, registration and transfer safeguards, including the 2025 amendments. Regulation 10 addresses autonomous and semi-autonomous systems and can matter to assistant integrations. June 2026 regulatory proposals require an adoption check; do not treat consultation text as operative.

Abu Dhabi Global MarketADGM Data Protection Regulations 2021 and applicable rulesIn force; substantial-public-interest rules added in 2025Narrow disclosure, correction and purpose evidence align with the accountability framework.

Apply ADGM-specific controller/processor, registration, special-category and impact-assessment rules. Certain sensitive-data grounds require an Appropriate Policy Document. Transfers outside ADGM need a permitted route; approved mechanisms include ADGM clauses and an ADGM addendum to EU clauses. A transfer to the wider UAE is not automatically internal to ADGM.

Saudi ArabiaPersonal Data Protection Law (PDPL), as amended, implementing regulations and transfer regulationsIn forceSpecific purposes, limited disclosure and traceable choices support the PDPL principles.

Assess the Saudi conditions for sensitive data, direct marketing, rights, DPO/registration duties and overseas transfers. Apply the current transfer regulation, local safeguards and risk-assessment requirements rather than assuming an EU agreement or general consent is sufficient. Determine scope for processing Saudi residents' data from abroad and any sector-specific restrictions.

BahrainPersonal Data Protection Law No. 30 of 2018 and implementing ordersIn force; 2022 orders are materialConsent evidence, purpose limits and access/correction support the local framework.

Assess notification and prior-authorisation procedures, sensitive-data conditions and the 2022 implementing orders. Overseas transfers follow the local adequate-country, authorisation or exception routes, including Order 42/2022. Order 45/2022 addresses sensitive processing. Personal permission does not substitute for a required authority approval.

QatarPersonal Data Privacy Protection Law No. 13 of 2016In forceClear purposes and granular permissions support transparency and control over use.

Article 16 requires permission from the competent authority before processing personal data of a special nature, including relevant health, religious and children's data. Obtain the applicable permit as well as satisfying consent and other duties. Assess marketing, security and cross-border risks separately. Qatar Financial Centre has a separate regime outside this entry.

OmanPersonal Data Protection Law, Royal Decree No. 6 of 2022, and Ministerial Decision No. 34/2024In force; full regulation enforcement from February 2026Narrow permissions, withdrawal and retention controls support the law and executive regulation.

Article 5 data processing needs a Ministry permit; verify the covered categories before accepting health or other sensitive context. The executive regulation also addresses children, rights, breach handling and overseas flows. Track permit conditions and validity. A grant or a submitted application is not the required regulatory permission.

EgyptPersonal Data Protection Law No. 151 of 2020 and Executive Regulations No. 816 of 2025Law and 2025 executive regulations; licensing transition requires reviewSpecific purposes, notice evidence and correction support the electronic-data framework.

The PDPC now publishes the licensing and permit framework: do not describe the executive regulations as still absent. Assess controller/processor licensing, registered DPOs, sensitive-data formalities and direct marketing. Cross-border disclosures need the applicable licence/permit or a permitted Article 15 exception. Confirm transition deadlines and procedures for the actual launch.

Africa

Jurisdiction and main regulationHow Autonym can helpLocal notes and sources
South AfricaProtection of Personal Information Act 4 of 2013 (POPIA)In forcePurpose limits, correction and controlled disclosure support POPIA's conditions for lawful processing.

Use the local responsible-party/operator roles, information-officer duties and special-personal-information conditions. Section 57 prior authorisation can apply to certain identifier-linking activities and transfers of special or children's information to countries without adequate protection. Section 72 governs foreign transfers. Assess direct-marketing consent separately; a grant is not regulatory authorisation.

NigeriaNigeria Data Protection Act 2023 and General Application and Implementation Directive (GAID) 2025In force; GAID 2025 appliesLimited purposes, rights support and accountable permissions fit the Act's structure.

Use the Act and GAID, not the older NDPR alone. Assess designation and registration as a controller or processor of major importance, DPO and audit-return requirements, sensitive-data conditions, high-risk assessments and transfers. A technical conformance declaration does not establish registration with the NDPC.

KenyaData Protection Act 2019 and the 2021 implementing regulationsIn force; September 2026 sensitive-category proposal is a draftPurpose-specific access, correction and deletion support individual rights.

Health data has additional section 46 provider/professional-confidentiality conditions; ordinary consent alone is not the whole assessment for a general context host. Apply registration rules and exemptions, transfer safeguards and any applicable localisation rules. ODPC's September 2026 proposal to expand sensitive categories must be checked for final adoption before treating it as law.

GhanaData Protection Act 2012 (Act 843)Act 843 is the baseline; replacement draft needs enactment checkPurpose limits and an accessible, correctable record support the data protection principles.

Controllers must assess registration before processing, special personal data, security, rights and overseas recipients. Registration particulars include purposes, recipient categories and destination countries. The Commission published a 2025 replacement draft; this review does not establish enactment. Do not substitute that draft for the operative law.

UgandaData Protection and Privacy Act 2019 and Regulations 2021In forceVisible purposes, correction and withdrawal support accountability and individual rights.

Assess the Act's extraterritorial scope, registration as a collector/controller/processor, annual renewal and local DPO/incident duties. Overseas processing or storage needs the applicable adequacy or consent conditions under the Act and regulations. Corrections may need communication to earlier recipients; changing the current record alone is not enough.

RwandaLaw No. 058/2021 relating to the protection of personal data and privacyIn forceDefined transfer categories, correction and retention controls support the law's requirements.

Distinguish permission to transfer from permission to store abroad. Article 50 requires a valid authority-issued authorisation for overseas storage; Articles 48-49 govern foreign sharing/access and contracts. Apply registration and sensitive-data conditions. A lawful recipient transfer or EU cloud contract does not automatically authorise foreign storage or backups.

MauritiusData Protection Act 2017 (Act 20/2017)In forcePurpose limitation, rights support and proportionate retention align with the framework.

Assess controller/processor registration, special-category conditions, impact assessment and prior consultation where required. Section 36 specifies overseas-transfer routes; document the applicable safeguards or exception. Automated decision rights and local breach duties require processes beyond the read log.

MoroccoLaw No. 09-08 on protection of individuals in the processing of personal dataIn forcePurpose-specific collection and correction support transparency and limited use.

Assess CNDP declarations and prior authorisation, particularly for sensitive data and national identity numbers. Foreign-transfer formalities are separate, and the related underlying processing must already have the required approval. A person's consent or an Autonym recipient registration does not replace a CNDP filing or authorisation.

TunisiaOrganic Law No. 2004-63 on Personal Data Protection and implementing decreesIn forceLimited purposes, access and correction provide useful support subject to the local approval framework.

Apply declaration and authorisation procedures and the specific restrictions on sensitive and health information. Article 52 requires INPDP authorisation for overseas transfers; health processing can also require prior permission. Do not enable a foreign assistant on the strength of consent alone. Assess special procedures for children and each intended use.

BotswanaData Protection Act 2024 (Act No. 18 of 2024)Replacement Act commenced 14 January 2025Defined purposes, limited disclosure and rights support fit the replacement framework.

Use the 2024 replacement Act rather than an undated reference to the earlier legislation. Assess its scope, lawful and sensitive-processing conditions, rights, security, officer/assessment triggers and cross-border provisions against the current legal text and implementing measures. Government material confirms the January 2025 commencement.

ZambiaData Protection Act 2021 (Act No. 3 of 2021) and General Regulations 2024In force; local storage is a central deployment issueControlled access and export are useful only within the permitted storage and transfer arrangements.

Section 70 requires processing and storage on a server or data centre in Zambia; assess any applicable category restrictions and authorised arrangements. Section 71 separately sets foreign-transfer conditions. The regulator's registration process flags separate transfer authorisation. Do not assume overseas-only hosting, encrypted backups or personal consent satisfy these obligations.

ZimbabweCyber and Data Protection Act 2021 and Statutory Instrument 155 of 2024In force; controller licensing rules applyNarrow purposes, access evidence and correction support accountable processing.

Assess POTRAZ data-controller licensing and exemptions, DPO requirements, sensitive-data conditions and overseas sharing. SI 155/2024 provides 12-month licences and renewal procedures, and notification of intended foreign transfers. A valid technical grant is not a controller licence; track both approval scope and expiry.

US state differences that affect the design

A single “US compliant” switch would hide material differences. These notes expand the named state examples and add Washington’s consumer-health regime. Coverage thresholds, exemptions and current regulations must be assessed for the particular deployment.

Virginia

Provide access, correction, deletion, portability and an appeal route. Separate sensitive-data consent and targeted-advertising or consequential-decision opt-outs from ordinary read permission. Apply the Act's coverage and exemptions to the actual business.

Attorney General: consumer rights
Colorado

Covered controllers must recognise Global Privacy Control for relevant sale and targeted-advertising opt-outs from 1 July 2024. A later browser signal must be able to stop an affected use even if an earlier Autonym grant remains technically valid.

Attorney General: universal opt-out
Connecticut

July 2026 changes extend sensitive-data protections and coverage. Further changes begin on 1 October 2026. Check the operative version, including health and children's data, instead of relying on the original 2023 threshold summary.

Attorney General: current and upcoming changes
Texas

Coverage differs from the turnover or volume tests used elsewhere. Small businesses generally have an exemption but must obtain consent before selling sensitive data. Covered controllers need rights and appeal routes, sensitive-data consent and required assessments and contracts.

Attorney General: TDPSA
Oregon

From 1 January 2026, sale of precise geolocation is prohibited and covered businesses must honour universal opt-out signals. Child-specific restrictions also apply. Consent does not make a prohibited sale permissible; Autonym's advertising rules already exclude location.

Department of Justice: business guidance
Montana

Use the amendments effective 1 October 2025, including changed coverage and stronger safeguards. Assess the current threshold, sensitive-data rules, children's protections and preference-signal obligations before enabling an optional advertising recipient.

Department of Justice: current Act
Delaware

The privacy notice must cover Delaware rights, and consumers need an appeal route. Apply the local sensitive-data and children's protections and confirm applicable preference-signal dates. A generic national notice must actually deliver the state-specific rights.

Department of Justice: privacy FAQ
New Jersey

Assess the Act's sensitive-data categories, consumer rights and opt-outs. The Attorney General has published proposed implementing rules; a proposal must not be treated as an operative rule. Check for final adoption before relying on its detailed procedures.

Attorney General: proposed rules
Maryland

Sensitive-data processing must be strictly necessary to provide or maintain a specifically requested product or service; sensitive-data sale is prohibited. Additional restrictions cover sale and targeted advertising involving people known or reasonably expected to be under 18. Broad consent does not override these limits.

General Assembly: section 14-4707
Minnesota

The law provides additional rights concerning consequential automated decisions, including questioning results and reassessment using corrected data. A recipient must support the applicable explanation and review process; an Autonym read receipt alone cannot provide it.

Attorney General: MCDPA rights
Washington consumer health data

The My Health My Data Act can cover health information and inferences outside HIPAA. Separate sale authorisation, collection/sharing rules and deletion duties require assessment. A general health-data read grant is not every required authorisation.

Attorney General: health data and privacy

Sources, scope and remaining uncertainty

This guide prioritises legislation, commencement orders and regulator guidance available on the review date. Each jurisdiction links to its sources. The US inventory also uses NCSL’s legislative register. English summaries and translations are aids; the authoritative local text and current implementing measures govern.

We distinguish operative law from future commencement and proposals. Unresolved points are stated in the relevant entry, including Montenegro’s replacement proposal and confirmation of Hong Kong’s transfer provision. An unresolved point is a deployment check, not permission to proceed. Sector laws, workplace rules, communications rules and countries outside this list can impose additional obligations.

The “How Autonym can help” column is the project’s design assessment, not a regulator’s endorsement. A real deployment needs a qualified assessment of its facts and evidence that its controls work. This guide concerns the standard; the website privacy noticeexplains how this site handles data.