SSS · Cross-Border Data Transfers

Our parent company in Germany has signed SCCs; is that sufficient for the KVKK too?

No — the two regimes use separate instruments. The EU side is secured with the SCCs, the Türkiye side with the KVKK standard contract; we set the two up as a single, non-conflicting package…

Updated · July 20261 min readCategory · Cross-Border Data Transfers
Short answer

No — the two regimes use separate instruments. The EU side is secured with the SCCs, the Türkiye side with the KVKK standard contract; we set the two up as a single, non-conflicting package.

No — the two regimes use separate instruments. The EU side is secured with the SCCs, the Türkiye side with the KVKK standard contract; we set the two up as a single, non-conflicting package.

The KVKK standard contract carries its own mandatory clauses fixed by the Authority; it cannot simply mirror the SCC text. Sign the two instruments as one coordinated set covering the same data flow, and remember the Türkiye-side contract is separately notified to the Authority within five business days of signing.

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Cross-Border Data Transfers

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