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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

GeorgiaChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Waking up

In one paragraph: Georgia copied the European model in 2023: data can leave the country, but only to a destination the supervisor has approved, or with a permit, or under a narrow exception. There is no general rule forcing data to stay. The big change is who is in charge — on 2 March 2026 the independent privacy watchdog was replaced by the State Audit Office, and we could not verify that it has issued a single decision since.
The catch: Two things break the calm headline. Telephone and internet connection records are copied into a state-held database inside Georgia, so telecoms cannot treat that data as ordinary business data. And the same State Audit Office that now polices privacy also runs the public register of foreign-funded organisations.
Does this apply to me?: Yes. The law catches a company with no office in Georgia if it uses technical means located in Georgia to handle people's data. There is no revenue or headcount threshold to duck under. Worse, a foreign company in that position must appoint a representative in Georgia and register that person with the supervisor BEFORE it starts processing — the only escape is being based in the European Union or in a country the European Union has already approved.High confidence
Can the data leave the country?: Yes, with paperwork. Data may go abroad if the destination country has been judged to give good enough protection, or if the supervisor grants a permit for the contract you have signed, or under a short list of narrow exceptions such as the person's written consent after being told the risks. Nothing in the general law forces data to stay in Georgia. The one place data really does stay is telecoms: a copy of who called whom, and when, sits in a state-run database inside the country.High confidence
What do I have to do to send it abroad?: The model is an approved-destinations list, with a permit as the back-up. The supervisor decides which countries offer good enough protection and publishes that decision as a formal act; if your destination is not on it, you need a permit for your contract, or you fall back on a narrow exception such as written consent. We could not find the current published list, so we cannot tell you today which countries are on it — treat that as the single biggest open question in this record.Medium confidence
Who enforces this — and are they actually working?: This is where Georgia surprises people. Until 1 March 2026 the job belonged to the Personal Data Protection Service, an independent watchdog. From 2 March 2026 the law hands the same job to the State Audit Office — the body that audits government spending — and its head, the Auditor General, now signs the privacy rules. We can prove the handover happened, because the Auditor General reissued two of the privacy rulebooks at the end of March 2026. We could not find a single enforcement decision published since the handover.Medium confidence
How long must I keep it, and when must I delete it?: The ceiling is clear: keep personal data only as long as you need it for the purpose you collected it for, then erase, destroy or strip out the identifying parts, unless another law tells you to keep it. The floors are scattered across tax, accounting and sector laws that we could not open on an official site today. In telecoms the direction is reversed — the content of a call or message must be destroyed at once, while the record of who contacted whom can be copied into a state database and kept for a period set by a separate law.Medium confidence
What happens when something goes wrong?: Two clocks. If personal data is lost, leaked or wrongly handled, you have 72 hours from spotting it to tell the supervisor, and you must keep your own record of the incident and what you did about it. If you run a system the government has listed as critical to the country, you must tell the national computer emergency response team immediately — no fixed number of hours, which in practice means the same day. If both apply to you, both run at once.High confidence
What's the trap?: Five. First, the regulator changed identity on 2 March 2026, so a privacy notice or contract naming the Personal Data Protection Service now points at a body the law no longer mentions. Second, a foreign company must register a representative in Georgia before it starts, not after. Third, a child is anyone under 16, so a European sign-up flow tuned to 13 will be wrong here. Fourth, direct marketing always needs consent, even if you bought the list lawfully. Fifth, the same State Audit Office that now polices privacy also runs the public register of foreign-funded organisations, which must publish detailed information about themselves.Medium confidence
What's about to change?: Nothing new is scheduled to start in the privacy law itself — we checked the current text on 18 August 2026 and found no provisions waiting on a future date. The live story is the handover: the Auditor General is reissuing the four rulebooks inherited from the old watchdog, and two of the four were reissued in March 2026. The rest of the risk sits in switches the government can already flip without a new law.Medium confidence
Hardest industry wall: Telecoms — საქართველოს კანონი ელექტრონული კომუნიკაციების შესახებ

The eight framework questions answered for each selected country
Question	TurkeyChecked 18 August 2026	GeorgiaChecked 18 August 2026
The three ratings	Depends on your industry Work: High Enforcement: Active	Yes, with paperwork Work: High Enforcement: Waking up
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.	Georgia copied the European model in 2023: data can leave the country, but only to a destination the supervisor has approved, or with a permit, or under a narrow exception. There is no general rule forcing data to stay. The big change is who is in charge — on 2 March 2026 the independent privacy watchdog was replaced by the State Audit Office, and we could not verify that it has issued a single decision since.
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.	Two things break the calm headline. Telephone and internet connection records are copied into a state-held database inside Georgia, so telecoms cannot treat that data as ordinary business data. And the same State Audit Office that now polices privacy also runs the public register of foreign-funded organisations.
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. The law catches a company with no office in Georgia if it uses technical means located in Georgia to handle people's data. There is no revenue or headcount threshold to duck under. Worse, a foreign company in that position must appoint a representative in Georgia and register that person with the supervisor BEFORE it starts processing — the only escape is being based in the European Union or in a country the European Union has already approved.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. Data may go abroad if the destination country has been judged to give good enough protection, or if the supervisor grants a permit for the contract you have signed, or under a short list of narrow exceptions such as the person's written consent after being told the risks. Nothing in the general law forces data to stay in Georgia. The one place data really does stay is telecoms: a copy of who called whom, and when, sits in a state-run database inside the country.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	The model is an approved-destinations list, with a permit as the back-up. The supervisor decides which countries offer good enough protection and publishes that decision as a formal act; if your destination is not on it, you need a permit for your contract, or you fall back on a narrow exception such as written consent. We could not find the current published list, so we cannot tell you today which countries are on it — treat that as the single biggest open question in this record.Medium 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	This is where Georgia surprises people. Until 1 March 2026 the job belonged to the Personal Data Protection Service, an independent watchdog. From 2 March 2026 the law hands the same job to the State Audit Office — the body that audits government spending — and its head, the Auditor General, now signs the privacy rules. We can prove the handover happened, because the Auditor General reissued two of the privacy rulebooks at the end of March 2026. We could not find a single enforcement decision published since the handover.Medium 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	The ceiling is clear: keep personal data only as long as you need it for the purpose you collected it for, then erase, destroy or strip out the identifying parts, unless another law tells you to keep it. The floors are scattered across tax, accounting and sector laws that we could not open on an official site today. In telecoms the direction is reversed — the content of a call or message must be destroyed at once, while the record of who contacted whom can be copied into a state database and kept for a period set by a separate law.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	Two clocks. If personal data is lost, leaked or wrongly handled, you have 72 hours from spotting it to tell the supervisor, and you must keep your own record of the incident and what you did about it. If you run a system the government has listed as critical to the country, you must tell the national computer emergency response team immediately — no fixed number of hours, which in practice means the same day. If both apply to you, both run at once.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. First, the regulator changed identity on 2 March 2026, so a privacy notice or contract naming the Personal Data Protection Service now points at a body the law no longer mentions. Second, a foreign company must register a representative in Georgia before it starts, not after. Third, a child is anyone under 16, so a European sign-up flow tuned to 13 will be wrong here. Fourth, direct marketing always needs consent, even if you bought the list lawfully. Fifth, the same State Audit Office that now polices privacy also runs the public register of foreign-funded organisations, which must publish detailed information about themselves.Medium 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	Nothing new is scheduled to start in the privacy law itself — we checked the current text on 18 August 2026 and found no provisions waiting on a future date. The live story is the handover: the Auditor General is reissuing the four rulebooks inherited from the old watchdog, and two of the four were reissued in March 2026. The rest of the risk sits in switches the government can already flip without a new law.Medium 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	Telecoms — საქართველოს კანონი ელექტრონული კომუნიკაციების შესახებ