Two-Minute Recap Of Recent Developments In Turkish Data Protection Law

Long Awaited Guidelines Published

The Turkish DPA has published its Guidelines on Cross-Border Transfer of Personal Data (“Guidelines”) which eliminate grey areas and standardize practice. They cover various transfer mechanisms such as adequacy decisions, appropriate safeguards, and exceptional transfers. The Guidelines also provide concrete examples to clarify common situations such as data transfers between subsidiaries and foreign parent companies and transfers by Turkish companies to foreign entities.

Novel Administrative Fine Amounts Announced

Administrative fines under the Turkish PDPL are revised annually to reflect the revaluation rate published at the beginning of each calendar year in accordance with Article 17 of the Misdemeanours Law No. 5326 and Article 298 of the Tax Procedure Law. For 2025, the revaluation rate has been set at 43.93% resulting in an increase in the number of administrative fines compared to 2024.