Israeli Privacy Shield

This skill provides compliance GUIDANCE. It does not replace legal counsel. Recommend consulting a privacy attorney (orech din specializing in prati'ut) for specific compliance decisions.

Step 1: Assess Security Level

The 2017 regulations define three security levels:

Sensitive data includes: Health, genetics, sexual orientation, political views, criminal record.

Step 2: Database Registration Check

Must register with Privacy Protection Authority if:

• Database has 10,000+ records AND used for direct marketing, OR
• Database has 10,000+ records AND contains sensitive information, OR
• Database owned by public body, OR
• Database used for credit/financial information services

Registration URL: https://www.gov.il/he/departments/privacy_authority

Step 3: Consent Requirements

Israeli law requires consent for:

• Collection of personal data
• Use beyond the original purpose
• Transfer to third parties
• Cross-border transfer

Consent must be: Informed, specific, freely given Exceptions: Legal obligation, vital interests, public interest, legitimate interest (limited)

Step 4: Cross-Border Transfer Rules

Personal data transfer outside Israel requires:

• Recipient country has adequate protection (EU, UK, few others), OR
• Contractual safeguards (similar to GDPR SCCs), OR
• Data subject consent (informed and specific), OR
• Listed exemptions (necessary for contract, legal proceedings, etc.)

Note: Israel has EU adequacy decision — transfer TO EU is generally straightforward.

Step 5: Breach Notification

Under 2017 regulations:

1. Severe security incident: Report to Privacy Protection Authority "without delay"
2. No specific hour deadline (unlike GDPR's 72 hours), but "without delay" interpreted as quickly
3. Notify affected individuals if breach may cause them significant harm
4. Document: All incidents, response actions, and decisions

Step 6: Compliance Checklist

For each assessed entity, verify:

• Database registration (if required)
• Privacy policy published (Hebrew, accessible)
• Consent mechanisms in place
• Security measures per level (basic/medium/high)
• Data processing agreements with processors
• Cross-border transfer safeguards
• Breach response plan
• Data subject request handling process
• Employee training
• Security officer/DPO appointed (if required)

Example 1: SaaS Startup Compliance

User says: "I'm building a SaaS with Israeli customers, what privacy requirements apply?" Result: Assessment of security level, database registration need, privacy policy requirements, recommended consent mechanisms.

Example 2: Data Breach Response

User says: "We discovered a data breach affecting Israeli users" Result: Step-by-step breach response: contain, assess, notify authority, notify users if significant harm, document.

Example 3: Cross-Border Data Transfer

User says: "We need to transfer Israeli customer data to our US servers" Actions:

1. Assess data types for sensitivity level
2. Check if destination country has adequate protection
3. Determine transfer mechanism (adequacy, consent, contractual clauses)
4. Document compliance steps Result: Transfer compliance checklist with specific steps for US data transfer under Israeli Privacy Protection Law.

Scripts

• scripts/compliance_checker.py — Runs a full Privacy Protection Law compliance assessment: determines security level (basic/medium/high), checks database registration requirements, and generates a compliance checklist with all applicable controls. Run: python scripts/compliance_checker.py --help

References

• references/privacy-law-requirements.md — Detailed breakdown of the Privacy Protection Law 1981 and 2017 Security Regulations including database registration process, security level requirements, consent rules, cross-border transfer rules, breach notification procedures, and penalties. Consult when you need specific legal requirements, section numbers, or GDPR comparison details beyond what the instructions cover.

Error: "Unsure about security level"

Cause: Borderline case between basic/medium/high Solution: When in doubt, apply the higher level. The cost difference is small compared to non-compliance risk.