Transfer of Personal Data Outside Turkey Explained with a Simple Diagram.
Burak Ozdagistanli
Burak Ozdagistanli
FIP & CIPP/E & CIPM | Managing Partner at ?zda??stanli Ekici Attorney Partnership | Advisory Board Member at IAPP | General Secretary & Board Member at Veri Koruma Derne?i
Article 9 of the Data Protection Law covers how personal data can be transferred outside Turkey, however the wording of the Article is difficult and not very clear. Please see a simple chart showing how personal data can be transferred outside Turkey.
*Please be informed that the Diagram was inspired and prepared in line with the Diagram prepared by the Turkish Data Protection Authority.
FIP & CIPP/E & CIPM | Managing Partner at ?zda??stanli Ekici Attorney Partnership | Advisory Board Member at IAPP | General Secretary & Board Member at Veri Koruma Derne?i
7 年Thank you for your valuable comment and I should reply by stating that you are correct and we shall add that the diagram was inspired by the Turkish DPA Brochure. Having said that, while the diagram is similar to the diagram in the Turkish DPA Brochure, it is not a mere translation. Please note that there are differences in the diagram specifically as to transfer of personal data with a data transfer agreement. In the brochure prepared by the DPA, it is stated that personal data can be transferred if the receiving country and the sending country undertake protection in writing. However, Art. 9 p2 b of the Law states that it is the data controllers in the receiving and the sending countries that must undertake protection in writing, not the countries. As mentioned above and pointed out by you, we will add a credit to the Turkish DPA .
FIP, CIPP/E, CIPM ? Founding Partner at MET+Partners
7 年I wish you mentioned the source as the diagram was taken by Turkish DPA Brochures linked below page 6. But thank you anyway translating into English. https://kvkk.gov.tr/yayinlar/K%C4%B0%C5%9E%C4%B0SEL%20VER%C4%B0LER%C4%B0N%20YURTDI%C5%9EINA%20AKTARILMASI.pdf
Chief Information Officer - Managing Director/Senior Advisor
7 年Congratz. Looks like a wonderfull diagram. However its impossible to see it via your post as the diagram does not bigger. Would be great to view in more detail :).