KVKK service
Türkiye Cross-Border Data Transfer Support
Understand how personal data connected with Türkiye is hosted, accessed, supported, and transferred across borders.
A practical service built around your evidence
Transfer reviews work best when contracts, system architecture, vendor operations, and privacy records describe the same reality. We help build that shared view and identify gaps that need legal, procurement, security, or operational action.
The service can focus on a single vendor or product, or create a broader inventory of transfers connected with Türkiye. The output is designed for continuing use as systems and suppliers change.
Preparing for the first discussion
Include foreign administrator access, overseas support teams, and supplier subprocessors when preparing the Turkish transfer map. For each relationship, identify the controller or processor role, data categories, purpose, destination, contract, and technical access arrangements. Record whether the transfer is continuing, planned, or exceptional so those situations can be assessed on their own facts. Bring the current inventory and privacy information to the same review. The outcome should connect the relevant transfer mechanism and any required formalities with the real data flow, rather than treating a signed document as proof that every overseas use has been addressed.
Service outputs
What you receive
The exact scope is confirmed before work begins. These are the core outputs normally used to turn the review into accountable action.
Türkiye transfer map
Parties, purposes, data, systems, countries, access patterns, and onward transfers.
Arrangement review
A review of relevant transfer documents and supporting operational evidence.
Safeguards assessment
A practical record of contractual, technical, and organisational protections.
Action roadmap
Prioritised updates for contracts, vendors, security, notices, inventories, and approvals.
How we work with your team
Confirm the scope
We agree the business question, processing, stakeholders, locations, deadlines, and evidence needed for a useful review.
Gather reliable evidence
We collect the relevant records, system and vendor information, existing documents, and input from accountable teams.
Complete the review
We test the current position, make assumptions explicit, resolve inconsistencies, and identify practical improvements.
Deliver and maintain
You receive decision-ready outputs, prioritised actions, accountable owners, and clear triggers for future review.
How we help
See how this service fits your organisation
Use the sections below to understand what we review, what you receive, what your team provides, and how you can keep the result useful after delivery.
01 · Fit
Is Turkish cross-border data transfer compliance right for your organisation?
Use this service when you are a Turkish or foreign controller that needs to understand overseas transfers, group access, cloud hosting, support, vendors, or recipients connected to Türkiye. We can focus on one flow or establish a repeatable local transfer review.
Turkish transfer work is needed when personal data moves abroad through a cloud platform, group company, support team, analytics tool, or supplier and the documentation does not reflect the actual route. The review focuses on the Turkish controller or processor context, recipients, purpose, data, countries, contracts, safeguards, and any registry or notice connection.
02 · Decision
What you will be able to decide
The organisation needs to know who transfers what data, for which purpose, to which recipient and location, under which documents, with which safeguards, and what local or contractual action is needed. A transfer record should support a real approval and refresh decision.
You should leave knowing which cross-border routes are in scope, what document or approval supports each route, which safeguards are realistic, what residual risk remains, and who owns the decision. We distinguish storage, remote access, support, and onward transfer because the same supplier may create several Turkish questions.
03 · Trigger
When to bring us in
A cloud provider, foreign group service, analytics tool, support arrangement, new subprocessor, customer request, or architecture change can reveal that Turkish transfer facts are unclear. A global transfer assessment may not capture the local controller, notice, registry, or recipient details.
04 · Evidence
What we need from your team
Use system architecture, exporter and importer, destinations, recipients, data categories, purposes, access, onward transfers, contracts, security, encryption, retention, notices, and registry information. Compare the legal documents with what administrators, vendors, and support teams can actually access.
Bring Turkish processing and entity facts, contracts, vendors and subprocessors, hosting and support locations, data categories, access roles, encryption, key management, retention, deletion, incident terms, notices, VERBİS information, and business purpose. We compare procurement and technical sources and identify claims that need a system or supplier owner to confirm.
05 · People
Who should join the work
Privacy and legal coordinate with IT, security, procurement, vendor management, product, and the business owner. Customer teams may add contract promises. The accountable controller owner should approve risk and assign the actions required to implement safeguards.
06 · Method
How we will work together
The work maps the flow, tests the applicable documents and safeguards, records the decision, assigns remediation, and sets a refresh trigger. Starting with one priority vendor can create a clear local question set for future onboarding and renewals.
The result can support a vendor approval, contract action, notice or registry update, architecture change, safeguard test, or risk acceptance. Each action gets a closing signal. If the route cannot be supported as designed, the business can decide whether to limit data, change the service, add controls, or pause the transfer while the issue is resolved.
07 · Output
What you will receive
Outputs may include a Turkish transfer map, assessment, contract and vendor actions, security dependencies, notice or registry updates, and maintenance triggers. The deliverables should sit with the processes that can change the transfer rather than in a disconnected privacy archive.
08 · Friction
What can make this harder
A contract-only review misses remote access, support, backup, logs, onward transfers, and changes in vendor architecture. A static list also becomes unreliable when no one updates it at renewal or when a new recipient is added in a system change.
09 · Maintenance
How you keep it current
Connect review to vendor onboarding, contract renewal, subprocessor changes, security architecture, customer diligence, incidents, and registry updates. Reassess when destination, data, purpose, access, or safeguards change.
Reopen the Turkish transfer review after a new destination, subprocessor, hosting or support change, contract renewal, access expansion, encryption change, or new purpose. Keep it beside the vendor and VERBİS records. A stable global contract does not prove that the Turkish route remains stable.
10 · Boundaries
What stays with your organisation
Transfer support does not operate vendor controls, eliminate all risk, or replace specialist legal and security work. The controller remains responsible for accurate facts, lawful decisions, contracts, and implementation.
11 · Scope
What to prepare before you start
Bring the priority flow, parties, locations, access model, data categories, current contracts and notices, security material, registry information, deadline, and owner. A bounded first assessment is easier to approve and maintain.
- Turkish controller, processor, purpose, and data facts
- Storage, support, remote access, and onward routes
- Vendor, contract, subprocessor, and safeguard evidence
- Notice, registry, procurement, security, and risk owners
- Change trigger for destination or service updates
12 · Buyer brief
What your first working brief should contain
Describe the Turkish controller or processor role, purpose, data categories, countries, storage, remote access, support, onward route, vendors, subprocessors, contracts, retention, deletion, safeguards, notices, and VERBİS connection. Ask technical and procurement owners to confirm the route rather than relying only on a global contract. Include the business deadline and what would happen if the current transfer could not continue as designed.
Place the assessment beside the vendor, architecture, notice, and registry records. Track any contract action, safeguard, access restriction, service change, risk acceptance, or approval with closing evidence. Review after a new destination, subprocessor, hosting change, support route, purpose, or access role. A Turkish transfer decision must reflect the route that operates in practice and the owner who can reopen it when the facts move.
13 · First test
What we will test first
The first Turkish transfer period tests controller or processor role, purpose, data, destination, storage, remote access, support, onward route, vendors, subprocessors, contracts, retention, safeguards, notices, and VERBİS connections. Technical and procurement owners should confirm what the service actually does. Track contract, access, safeguard, approval, notice, registry, or architecture actions with closing evidence. Reopen after a destination, hosting, subprocessor, support, purpose, or access change. The assessment should remain connected to the Turkish owners who can change or pause the route if the facts no longer support it.
14 · Working record
How the result stays usable
A useful result has a home after delivery. Keep the source evidence, decision, owner, scope, open actions, and next review together in a register, project record, contract file, or management routine that your team already uses. The format can be short; it just needs to make the next action and the reason for reopening the question visible. That is how professional input stays connected to the business instead of becoming a document that no one can find when the facts change.
15 · Progress
How you can judge progress
Judge progress by what your team can use and explain. Look for a supported decision, an owner who understands the action, a route that works in practice, and evidence that the agreed output reached the right system, notice, contract, ticket, or meeting. A large document or a high-level score is not enough on its own. The stronger signal is fewer repeated questions, clearer escalation, and a review date that responds to actual change.
16 · Proportion
What a proportionate scope looks like
A proportionate scope should leave you with enough detail to act and enough clarity to know what remains outside the work. We will ask for the facts that can change the answer, explain material uncertainty, and keep specialist dependencies visible. You should be able to tell a manager what was reviewed, an operating owner what to do next, and a future reviewer what event would reopen the question. That balance protects your budget and makes the result more likely to stay useful after delivery.
17 · Handoff
What remains with your organisation
Your organisation remains responsible for the processing, resources, implementation, and final business decision. We can review the supplied facts, provide professional direction, prepare agreed outputs, and make open issues easier to act on. Bring in security, technical, employment, communications, or specialist legal expertise when the question needs it. Before you buy, name the decision, evidence, owner, deadline, and boundary so the selected scope is proportionate and easy to judge.
In practice
See what you can expect
Each view shows a different part of the buyer journey: the evidence, decision, working route, safeguards, and review point behind the service.






Frequently asked questions
Can you review one cloud provider first?
Yes. A focused review can resolve an urgent product, customer, procurement, or management question.
Who should contribute to the review?
Common contributors include the business owner, IT or security, procurement, legal or privacy, and the vendor.
Can transfer reviews become part of procurement?
Yes. We can define intake questions, required evidence, reviewers, approvals, and refresh triggers for new and renewed vendors.
Related Türkiye services
KVKK Compliance Programme
Build a practical Türkiye KVKK compliance programme with prioritised actions, clear ownership, documentation, and review routines.
Türkiye Data Breach Response Support
Coordinate Türkiye personal data breach assessment, documentation, response actions, and authority communication support.
Türkiye Privacy Notice Support
Create clear Türkiye privacy notices that match actual processing, collection channels, responsible entities, and internal records.
Türkiye KVKK Staff Training
Practical KVKK training for employees, leadership, and teams responsible for personal data in Türkiye.
Discuss the scope before you commit
Tell us what changed, what evidence you already have, and which decision or deadline the work needs to support.
Service information is general and does not replace advice based on the facts of a specific matter. Final scope, responsibilities, and deliverables are confirmed in the service documentation.
