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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
LatviaChecked 18 August 2026
Depends on your industryWork: HighEnforcement: Active
In one paragraph
Latvia follows European Union privacy rules, so personal data may leave the country once the right paperwork is in place. But Latvia adds its own walls. Accounting records may not be stored outside the European Union at all. Phone and internet companies must hold call records for eighteen months. Banks need the central bank's blessing before handing systems to an outside supplier.
The catch
The relaxed European headline stops being true the moment you touch four things. (1) Accounting records: paper must stay in Latvia and electronic copies must stay inside the European Union, so a United States accounting or resource-planning cloud is unlawful for a Latvian company. (2) Telecoms: eighteen months of call and connection records, plus a gag on telling the customer. (3) Banking: significant outsourcing needs a filing with the central bank and a thirty-working-day wait. (4) State critical computer systems: the supplier and its owners must be from a NATO, European Union, European Free Trade Association or NATO Indo-Pacific partner country, and audit information may only be handled inside that same group of countries.
Does this apply to me?
Yes. A company with no office in Latvia is still caught if it offers goods or services to people in Latvia or watches what they do online. That reach comes from the European Union privacy regulation, which applies directly in Latvia. There is no size or revenue threshold to duck under. A company based outside Europe normally has to name a contact person inside the European Union. Latvia's own privacy act adds national detail rather than a separate territorial test.High confidence
Can the data leave the country?
Personal data can leave Latvia, but the answer flips depending on what kind of data it is. For ordinary personal data the European rules apply: send it anywhere with the right legal instrument. For accounting records the door is shut at the edge of the European Union — paper stays in Latvia, electronic files stay inside the European Union. Phone and internet companies must keep eighteen months of call records. Banks must clear big outsourcing deals with the central bank first. State critical computer systems can only be supplied and audited from allied countries.High confidence
What do I have to do to send it abroad?
For personal data the model is a permission list, not a ban list. You may send data to a country the European Commission has approved, or use the European Union's standard contract template, or use approved group-wide rules. The approved list is real and long — it includes the United Kingdom, Japan, South Korea, Switzerland and, for self-certified companies only, the United States. For accounting records none of this helps: the wall is geographic, and no contract unlocks it.High confidence
Who enforces this — and are they actually working?
The privacy regulator is the State Data Inspectorate, and it is genuinely working, not a name on a door. In 2025 it took 1,034 complaints, ran 1,396 checks, applied corrective measures 62 times and issued fines totalling 326,400 euros (about $355,000), the largest single fine being 300,000 euros (about $327,000). It has about 32 staff. In the first half of 2026 it received 832 complaints and opened 73 checks of its own motion. Separate regulators handle banking, telecoms and cyber security, and all are staffed.High confidence
How long must I keep it, and when must I delete it?
Latvia has an unusually crowded set of minimum keeping periods and one surprising maximum. You must keep accounting registers ten years and supporting documents at least five. Phone and internet companies must keep call records eighteen months. Medical records run from one year to forty years depending on the form. In the other direction, security audit trails must normally be deleted after one year — shorter than many global logging policies allow.High confidence
What happens when something goes wrong?
Count at least two clocks, and often three. If personal data is exposed you have 72 hours to tell the State Data Inspectorate, and you must tell affected people without delay if the risk to them is high. If you run an essential or important service you also have 24 hours to send an early warning to the cyber incident response body, then 72 hours for a first report — and trust service providers get only 24 hours for that first report too. Banks have a third set of reporting duties under European financial rules.High confidence
What's the trap?
Five things that are not in the summary. One: a child can consent from age 13, not 16, so a Latvian teenager can sign up without a parent. Two: mishandling personal data can be a crime, not just a fine, and a company's responsible employee faces up to four years in prison. Three: your accounting system cannot sit outside the European Union, and its entries must be made in Latvian. Four: audit logs must usually be deleted after one year. Five: a bank cannot move systems to a new supplier until it has filed with the central bank and waited thirty working days.High confidence
What's about to change?
Two dated items and three switches. On 12 January 2027 the European Data Act bans cloud providers from charging customers to move their data out — a real change to cloud contracts used in Latvia. On 14 October 2026 Latvia holds its next data protection specialist qualification examination. The switches: the government may still write binding rules on where computer systems are hosted and has not done so; the European Union's approval of United States data transfers is under formal challenge; and the cyber security law is being amended piece by piece.Medium confidence
Hardest industry wall
  • All industries Grāmatvedības likums
  • Government Ministru kabineta noteikumi Nr. 397 "Minimālās kiberdrošības prasības"