Build a transfer map
Map where application data, backups, logs, analytics, email and support records go. Assess subprocessors and conditions of access from abroad. Record data categories, purpose, recipient, frequency and retention separately. Without a map, it is difficult to assess transfers correctly based only on a contract heading.
Use the current framework
KVKK Article 9 and the Authority's guide provide a framework involving adequacy decisions, appropriate safeguards and limited exceptional cases. The applicable path depends on the facts. Do not rely on old summaries or assume one legal basis fits every scenario. Review current decisions and documents with legal advisers.
Contract type and notification
If a standard contract is used, choose the text and process appropriate to the parties' roles. The Authority's notice states that standard contracts must be notified within five business days of signing. Verify the period and current procedure against official sources. Engineering supplies evidence of data flows; legal mechanisms and procedures require qualified assessment.
Track changes
A new monitoring tool, support team or region can change data flows. Supplier change notifications, subprocessor lists and periodic inventory reviews are therefore important. Local hosting may localize some flows but does not settle every transfer question. This content is not legal advice; verify the applicable mechanism against actual service conditions.
Pre-decision checklist
- Record recipients and data categories.
- Review the current KVKK guide.
- Track subprocessor changes.
Official sources
- KVKK — Kişisel Verilerin Yurt Dışına Aktarılması Rehberi
- KVKK — Yurt dışına aktarım / International transfers
- KVKK — Standart Sözleşme Bildirim Modülü
This content is not legal advice. Use current official sources and qualified advice when assessing your application.