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Two or three countries, side by side, one row per question. Pick up to 3.

Countries

TurkeyChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: Turkey lets personal data leave, but only after you build the paperwork yourself. The regulator has never declared a single country safe, so the approved-destination list is empty. Most companies use a government-published standard contract and must file it within five working days. The regulator is busy: it fined 876 organisations in 2025.
The catch: The general rule is 'paperwork, then you may send it'. That stops being true the moment you touch payments, banking, telecoms networks, public-sector systems or critical infrastructure. Payment and electronic money firms must keep their systems, their backups and their data inside Turkey, and may only use cloud providers the central bank has approved by name.
Does this apply to me?: Yes. A company with no office in Turkey is still caught, and it is caught harder than a local one. Any organisation based outside Turkey that decides why and how Turkish people's data is used must appoint a representative inside Turkey and sign up to the public register of data controllers before it starts processing. That representative has to be a company set up in Turkey or a Turkish citizen. Turkish small businesses can escape the register if they have fewer than 50 staff and a balance sheet under 100 million lira, but there is no such let-off for foreign companies.High confidence
Can the data leave the country?: It depends entirely on your industry, which is why Turkey is rated 'sectoral'. Under the general privacy law data may leave, but only after you put an approved safeguard in place, because the regulator has not yet declared any country safe. In payments and banking the answer flips to no: systems, backups and data have to sit inside Turkey. Public bodies, critical infrastructure, telecoms networks and health records all carry their own extra restrictions on top.High confidence
What do I have to do to send it abroad?: The model is an approved-destination list, and the list is empty. Nobody can rely on their country being blessed, so almost everyone uses one of the safeguards instead. The usual route is signing one of four standard contracts the regulator publishes, then telling the regulator within five working days of signing. Group companies can instead get binding corporate rules approved, and there is a permission route for bespoke undertakings, but that route almost always fails.High confidence
Who enforces this — and are they actually working?: The Personal Data Protection Authority, and it is fully up and running. In 2025 its board met 42 times, took 2,528 decisions, handled 12,512 complaints and fined 876 organisations a combined 352.5 million lira, which is roughly 8 million US dollars. It publishes named breach announcements most weeks. Financial, telecoms and insurance regulators enforce their own rules alongside it, and a new Cybersecurity Directorate has taken over the national cyber incident centre.High confidence
How long must I keep it, and when must I delete it?: Both directions apply, and the ceiling is unusual. Turkey does not give you a fixed number of months to delete by. Instead, once your reason for holding data runs out, you must erase it at your next scheduled clear-out, and any organisation on the public register has to publish a written retention and destruction policy setting those dates. The floor comes from ordinary commercial and tax law, which forces you to keep books and invoices for years.Medium confidence
What happens when something goes wrong?: There are at least three clocks. The privacy one is 72 hours: from the moment you learn that data has been taken unlawfully, you have three days to tell the Personal Data Protection Board, and you must tell the affected people as soon as you reasonably can. If you miss the 72 hours you must still report and explain why you were late. Companies based abroad have to report too, if people in Turkey are affected.High confidence
What's the trap?: Five things bite people. One: most fines are for paperwork, not privacy. Two thirds of the organisations fined in 2025 were punished for the public register, not for mishandling anyone's data. Two: the bespoke permission route for sending data abroad is close to a dead end, with 76 of 89 applications refused in 2025. Three: filing your standard contract invites inspection rather than closing the file. Four: your representative in Turkey must be Turkish. Five: no country is on the safe list, so there is no shortcut.High confidence
What's about to change?: Two dated items and one direction of travel. Retailers running loyalty cards have until 28 February 2027 to build a way of checking that the person at the till really owns the card, after the regulator extended the original deadline in July 2026. Public bodies are working to a July 2026 ruling on what they may publish online. And the government is pushing openly on data sovereignty, with the President chairing a cyber security meeting in May 2026 that treated data as a strategic asset.High confidence
Hardest industry wall: Payments — Odeme ve Elektronik Para Kuruluslarinin Bilgi Sistemleri ile Odeme Hizmeti Saglayicilarinin Odeme Hizmetleri Alanindaki Veri Paylasim Servislerine Iliskin Teblig
Banking — Bankalarin Bilgi Sistemleri ve Elektronik Bankacilik Hizmetleri Hakkinda Yonetmelik
Government — 2019/12 sayili Bilgi ve Iletisim Guvenligi Tedbirleri Genelgesi ve Bilgi ve Iletisim Guvenligi Rehberi

BrazilChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Active

In one paragraph: Brazil does not force data to stay inside the country. Personal data can leave, but since August 2025 you normally need a contract written by the regulator, word for word, signed with whoever receives it. Sending data to the European Union needs nothing extra. The regulator is awake and has started switching features off large platforms.
The catch: Brazil is often listed as a data-localisation country. It is not one. The old rule that pushed federal government email and data onto Brazilian systems was scrapped in 2018, and today's federal cloud rules do not require Brazilian soil. The real constraints are different in shape: banks must keep the central bank able to reach their data wherever it sits, and since July 2026 digital platforms must have an actual office and a legal representative inside Brazil.
Does this apply to me?: Yes. Brazil's privacy law reaches a company with no office in Brazil, as long as it collects data in Brazil or offers goods or services to people here. There is no size or revenue threshold that lets you out. The privacy law itself does not make you appoint anyone local — but two newer rules do, and if you run a digital platform you now need a registered office and a legal representative in Brazil.High confidence
Can the data leave the country?: Yes, with paperwork. Brazil has no rule making anyone keep a copy of anything inside the country — not for banks, not for hospitals, not even for the federal government's own cloud. What it has instead is a permission slip: before personal data leaves, you need one of a short list of approved legal grounds. Industry rules add conditions on top, but none of them is a wall.High confidence
What do I have to do to send it abroad?: Pick one of five routes. The easy one is the European Union: since January 2026 Brazil treats it as safe, so nothing extra is needed. For everywhere else, the normal route is a set of standard contractual clauses that the regulator itself wrote — you copy them into your contract exactly, and you may not edit them. A deadline to retrofit older contracts already passed, on 23 August 2025.High confidence
Who enforces this — and are they actually working?: The National Data Protection Authority, and it is genuinely working. A law passed in February 2026 gave it real independence, 200 new specialist jobs and its own budget. In August 2026 it ordered Discord to switch off live video streaming in Brazil within three working days, to protect children. Banking, telecoms, insurance and securities regulators enforce their own rules in parallel and have done so for years.High confidence
How long must I keep it, and when must I delete it?: Both directions, and they pull against each other. The floor: internet access providers must keep connection records for one year, websites and apps must keep access records for six months, and tax records need five years. The ceiling: the privacy law says personal data must be deleted once you have finished doing what you collected it for. Where the two clash, the legal duty to keep wins — the law lists that as an express reason to hold on.High confidence
What happens when something goes wrong?: Count three clocks, not one. Privacy: three working days to tell the regulator AND the affected people, once you have confirmed a breach that could really hurt them. Platform content: two hours to take down intimate images shared without consent, once notified. On top of that, banks report incidents to the central bank and telecoms operators report to the telecoms regulator under their own separate timetables.High confidence
What's the trap?: Five. (1) Your European standard contract is not automatically good enough — Brazil wrote its own clauses and you must copy them exactly, unedited, and the deadline to fix old contracts passed on 23 August 2025. (2) A child in Brazil is under 12 and an adolescent is 12 to 17, but the social media rule bites at 16 — accounts for anyone up to 16 must be tied to a parent's account, and asking users to state their own age is banned. (3) Since 20 July 2026 a digital platform needs an actual registered office in Brazil, not just a lawyer on retainer. (4) The biggest fine is not in the privacy law: the internet law allows up to 10 percent of your group's Brazilian revenue. (5) The regulator can order your database blocked or your processing suspended, which usually hurts more than any cheque.High confidence
What's about to change?: One firm date: January 2027, when the regulator moves from monitoring platforms to full enforcement of the children's digital rules. Brazil's artificial intelligence bill is still only a bill — it was sitting in a committee waiting for a report as recently as June 2026, so do not plan around it. The bigger risk is not new law: it is that the regulator can add or withdraw approved destinations for data transfers by publishing a single resolution, with no consultation.High confidence
Hardest industry wall: None found.

The eight framework questions answered for each selected country
Question	TurkeyChecked 18 August 2026	BrazilChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Active	Yes, with paperwork Work: High Enforcement: Active
In one paragraph	Turkey lets personal data leave, but only after you build the paperwork yourself. The regulator has never declared a single country safe, so the approved-destination list is empty. Most companies use a government-published standard contract and must file it within five working days. The regulator is busy: it fined 876 organisations in 2025.	Brazil does not force data to stay inside the country. Personal data can leave, but since August 2025 you normally need a contract written by the regulator, word for word, signed with whoever receives it. Sending data to the European Union needs nothing extra. The regulator is awake and has started switching features off large platforms.
The catch	The general rule is 'paperwork, then you may send it'. That stops being true the moment you touch payments, banking, telecoms networks, public-sector systems or critical infrastructure. Payment and electronic money firms must keep their systems, their backups and their data inside Turkey, and may only use cloud providers the central bank has approved by name.	Brazil is often listed as a data-localisation country. It is not one. The old rule that pushed federal government email and data onto Brazilian systems was scrapped in 2018, and today's federal cloud rules do not require Brazilian soil. The real constraints are different in shape: banks must keep the central bank able to reach their data wherever it sits, and since July 2026 digital platforms must have an actual office and a legal representative inside Brazil.
Does this apply to me?	Yes. A company with no office in Turkey is still caught, and it is caught harder than a local one. Any organisation based outside Turkey that decides why and how Turkish people's data is used must appoint a representative inside Turkey and sign up to the public register of data controllers before it starts processing. That representative has to be a company set up in Turkey or a Turkish citizen. Turkish small businesses can escape the register if they have fewer than 50 staff and a balance sheet under 100 million lira, but there is no such let-off for foreign companies.High confidence	Yes. Brazil's privacy law reaches a company with no office in Brazil, as long as it collects data in Brazil or offers goods or services to people here. There is no size or revenue threshold that lets you out. The privacy law itself does not make you appoint anyone local — but two newer rules do, and if you run a digital platform you now need a registered office and a legal representative in Brazil.High confidence
Can the data leave the country?	It depends entirely on your industry, which is why Turkey is rated 'sectoral'. Under the general privacy law data may leave, but only after you put an approved safeguard in place, because the regulator has not yet declared any country safe. In payments and banking the answer flips to no: systems, backups and data have to sit inside Turkey. Public bodies, critical infrastructure, telecoms networks and health records all carry their own extra restrictions on top.High confidence	Yes, with paperwork. Brazil has no rule making anyone keep a copy of anything inside the country — not for banks, not for hospitals, not even for the federal government's own cloud. What it has instead is a permission slip: before personal data leaves, you need one of a short list of approved legal grounds. Industry rules add conditions on top, but none of them is a wall.High confidence
What do I have to do to send it abroad?	The model is an approved-destination list, and the list is empty. Nobody can rely on their country being blessed, so almost everyone uses one of the safeguards instead. The usual route is signing one of four standard contracts the regulator publishes, then telling the regulator within five working days of signing. Group companies can instead get binding corporate rules approved, and there is a permission route for bespoke undertakings, but that route almost always fails.High confidence	Pick one of five routes. The easy one is the European Union: since January 2026 Brazil treats it as safe, so nothing extra is needed. For everywhere else, the normal route is a set of standard contractual clauses that the regulator itself wrote — you copy them into your contract exactly, and you may not edit them. A deadline to retrofit older contracts already passed, on 23 August 2025.High confidence
Who enforces this — and are they actually working?	The Personal Data Protection Authority, and it is fully up and running. In 2025 its board met 42 times, took 2,528 decisions, handled 12,512 complaints and fined 876 organisations a combined 352.5 million lira, which is roughly 8 million US dollars. It publishes named breach announcements most weeks. Financial, telecoms and insurance regulators enforce their own rules alongside it, and a new Cybersecurity Directorate has taken over the national cyber incident centre.High confidence	The National Data Protection Authority, and it is genuinely working. A law passed in February 2026 gave it real independence, 200 new specialist jobs and its own budget. In August 2026 it ordered Discord to switch off live video streaming in Brazil within three working days, to protect children. Banking, telecoms, insurance and securities regulators enforce their own rules in parallel and have done so for years.High confidence
How long must I keep it, and when must I delete it?	Both directions apply, and the ceiling is unusual. Turkey does not give you a fixed number of months to delete by. Instead, once your reason for holding data runs out, you must erase it at your next scheduled clear-out, and any organisation on the public register has to publish a written retention and destruction policy setting those dates. The floor comes from ordinary commercial and tax law, which forces you to keep books and invoices for years.Medium confidence	Both directions, and they pull against each other. The floor: internet access providers must keep connection records for one year, websites and apps must keep access records for six months, and tax records need five years. The ceiling: the privacy law says personal data must be deleted once you have finished doing what you collected it for. Where the two clash, the legal duty to keep wins — the law lists that as an express reason to hold on.High confidence
What happens when something goes wrong?	There are at least three clocks. The privacy one is 72 hours: from the moment you learn that data has been taken unlawfully, you have three days to tell the Personal Data Protection Board, and you must tell the affected people as soon as you reasonably can. If you miss the 72 hours you must still report and explain why you were late. Companies based abroad have to report too, if people in Turkey are affected.High confidence	Count three clocks, not one. Privacy: three working days to tell the regulator AND the affected people, once you have confirmed a breach that could really hurt them. Platform content: two hours to take down intimate images shared without consent, once notified. On top of that, banks report incidents to the central bank and telecoms operators report to the telecoms regulator under their own separate timetables.High confidence
What's the trap?	Five things bite people. One: most fines are for paperwork, not privacy. Two thirds of the organisations fined in 2025 were punished for the public register, not for mishandling anyone's data. Two: the bespoke permission route for sending data abroad is close to a dead end, with 76 of 89 applications refused in 2025. Three: filing your standard contract invites inspection rather than closing the file. Four: your representative in Turkey must be Turkish. Five: no country is on the safe list, so there is no shortcut.High confidence	Five. (1) Your European standard contract is not automatically good enough — Brazil wrote its own clauses and you must copy them exactly, unedited, and the deadline to fix old contracts passed on 23 August 2025. (2) A child in Brazil is under 12 and an adolescent is 12 to 17, but the social media rule bites at 16 — accounts for anyone up to 16 must be tied to a parent's account, and asking users to state their own age is banned. (3) Since 20 July 2026 a digital platform needs an actual registered office in Brazil, not just a lawyer on retainer. (4) The biggest fine is not in the privacy law: the internet law allows up to 10 percent of your group's Brazilian revenue. (5) The regulator can order your database blocked or your processing suspended, which usually hurts more than any cheque.High confidence
What's about to change?	Two dated items and one direction of travel. Retailers running loyalty cards have until 28 February 2027 to build a way of checking that the person at the till really owns the card, after the regulator extended the original deadline in July 2026. Public bodies are working to a July 2026 ruling on what they may publish online. And the government is pushing openly on data sovereignty, with the President chairing a cyber security meeting in May 2026 that treated data as a strategic asset.High confidence	One firm date: January 2027, when the regulator moves from monitoring platforms to full enforcement of the children's digital rules. Brazil's artificial intelligence bill is still only a bill — it was sitting in a committee waiting for a report as recently as June 2026, so do not plan around it. The bigger risk is not new law: it is that the regulator can add or withdraw approved destinations for data transfers by publishing a single resolution, with no consultation.High confidence
Hardest industry wall	Payments — Odeme ve Elektronik Para Kuruluslarinin Bilgi Sistemleri ile Odeme Hizmeti Saglayicilarinin Odeme Hizmetleri Alanindaki Veri Paylasim Servislerine Iliskin Teblig Banking — Bankalarin Bilgi Sistemleri ve Elektronik Bankacilik Hizmetleri Hakkinda Yonetmelik Government — 2019/12 sayili Bilgi ve Iletisim Guvenligi Tedbirleri Genelgesi ve Bilgi ve Iletisim Guvenligi Rehberi	None found.