Important Step in the Transfer of Personal Data Abroad

A Significant Step in the Transfer of Personal Data Abroad

As is known, the amendments made in 2024 to the Law on the Protection of Personal Data No. 6698 (“KVKK”) introduced several innovations regarding the methods of transferring personal data abroad.

As a result of these changes, Article 9/4-(a) of the KVKK now stipulates that personal data may be transferred abroad “if there is an agreement, which does not qualify as an international treaty, between foreign public institutions and organizations or international organizations and public institutions and organizations or professional organizations having the status of public institutions in Turkey, and if the Board grants permission for such transfer.”

Within this framework, for the first time, an agreement between the Ministry of Interior Directorate General of Migration Management and the United Nations High Commissioner for Refugees (UNHCR), defined as an “agreement not having the nature of an international treaty” was evaluated pursuant to Article 9/4-(a) of the KVKK and Article 11 of the Regulation on the Procedures and Principles Regarding the Transfer of Personal Data Abroad. The Personal Data Protection Authority (KVKK) granted permission for this transfer on October 21, 2025.

This decision marks one of Turkey’s first examples of data sharing with international organizations and is considered a noteworthy step in this field.

You can access the Authority’s announcement on the matter from [here].