For an overseas transfer, map the actual recipients and countries first, then document the relevant route under KVKK Article 9: adequacy, appropriate safeguards or a genuinely occasional transfer.
Map the transfer
Cloud hosting, remote support, email, analytics, group-company access and administration from abroad can all create transfers. Record data categories, persons, recipient, country, purpose, frequency and retention.
Choose the legal mechanism
Adequacy decisions, safeguards announced by the Board, standard contracts and binding corporate rules are distinct routes. Occasional exceptions should not become the standing basis for regular transfers.
Using standard contracts
Select the current template for the correct controller or processor scenario and do not make prohibited changes. Check signatures, language, notification timing and the technical and organisational measures in the annexes against current Board guidance.
KVKK and GDPR are separate
A flow may fall under both systems, but compliance with one does not automatically satisfy the other. Sub-processors, onward transfers, audit, breach notice, return and deletion of data need express treatment.
Relevant legislation and official sources
General legal information. Applicable law, jurisdiction, deadlines and remedies depend on the facts and current official texts; no outcome is guaranteed.
Content is for general information and is not personal legal advice. Contact alone does not establish a lawyer-client relationship.
Related practice areasData Protection · KVKK & GDPR