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ARTICLE · 25 FEBRUARY 2025

Data Residency In Turkey For 2025

Gün + Partners
Gün + Partners
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Yes, but under specific conditions. Before June 1, 2024, personal data could be transferred abroad only if explicit consent was obtained or if a legal basis other than consent existed.

TurkeyPrivacy
Begüm Yavuzdoğan Okumuş
Begüm Yavuzdoğan Okumuş
Seda Takmaz
Seda Takmaz
Yalçın Umut Talay
Yalçın Umut Talay
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Executive Summary: Data Residency in Turkey – Q&A Format

  1. Overview

1.1 General Personal Data

Q: Can personal data be transferred abroad?

A: Yes, but under specific conditions. Before June 1, 2024, personal data could be transferred abroad only if explicit consent was obtained or if a legal basis other than consent existed. These legal bases were outlined under Article 5 of the Data Protection Law (DPL). However, the applicability of these bases was limited due to the absence of an official safe country list. Under the new amendments, explicit consent is no longer the primary requirement for cross-border transfers.

Q: What are the safeguards for data transfers?

A: The law specifies several mechanisms that can be used to ensure adequate protection for cross-border data transfers. These include: (i) agreements between correspondent authorities, where public institutions or professional organizations in Turkey and their counterparts abroad establish

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