Turkish Data Protection Authority recently published two (2) recent announcements1 regarding the approval of undertaking letters which were drafted for cross-border transfer of personal data. These 2 decisions marked the first approvals of the Turkish Data Protection Authority for cross-border data transfers.
ELIG Gurkaynak has been assisting clients on all aspects of Turkish data protection law matters, including undertaking letters. A result of the drafting and negotiation processes with the Turkish Data Protection Authority, ELIG Gurkaynak obtained a successful outcome in terms of an undertaking letter submitted to the Turkish Data Protection Authority which was approved by Turkish Data Protection Authority following an evaluation period of 3 years. ELIG Gurkaynak assisted in all stages of the drafting, negotiation and approval stages, by evaluating the matter both from legal and business perspectives throughout the undertaking letter procedure, which is subject to a thorough and scrutinized evaluation by Turkish Data Protection Authority, and obtained a successful result through the approval of Turkish Data Protection Authority.
To date, Turkish Data Protection Authority published only 2 announcements for the approval of undertaking letters. We might expect this development to encourage or pave the way for other prominent companies to enter into the undertaking procedure, as there were not any precedents in which Turkish Data Protection Authority approved undertaking letters before this development.
Footnote
1 Please see the Turkish versions of the announcements at https://www.kvkk.gov.tr/Icerik/6867/TAAHHUTNAME-BASVURUSU-HAKKINDA-DUYURU and https://www.kvkk.gov.tr/Icerik/6898/TAAHHUTNAME-BASVURUSU-HAKKINDA-DUYURU. (Last accessed April 20, 2021).
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