Cross-Border Data Transfer
"What rules govern cross-border personal data transfers from Turkey?"
Quick Answer
Cross-border transfers require a KVKK Article 9 route: an applicable adequacy decision, a qualifying appropriate safeguard, or a narrowly applicable exceptional ground. A KVKK standard contract must use the correct party-role combination and be notified to the Authority within five business days after signing.
Scope and Legal Distinctions
KVKK Article 9 uses a tiered transfer framework: an applicable adequacy decision, an appropriate safeguard meeting the statutory conditions, or a narrowly applicable exceptional route. GDPR compliance alone does not provide a Turkish transfer basis.
What to Check in Practice
Map overseas hosting, support access and onward transfers. If using a KVKK standard contract, choose the correct controller/processor combination and notify the Authority within five business days after signing; retain authority documents and notification evidence.
Sources & Authorities
Statutory framework and official guidance for this definition.
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