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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

Saudi ArabiaChecked 18 August 2026

Yes, with paperworkWork: HighEnforcement: Waking up

In one paragraph: Data can leave Saudi Arabia, but never for free. You need a purpose the law allows, a written safeguard such as the government's own standard contract, and a written risk assessment that asks whether the transfer could harm the Kingdom itself. Banks need the central bank's written permission before anything goes abroad. The privacy regulator is fully set up but publishes no fines.
The catch: The 'paperwork and you can send it' answer is true for an ordinary business. It is false for banks and finance companies, where the central bank must give written no-objection first and cloud is expected to sit inside the country. It is also unsettled for government bodies and critical national infrastructure: the old rule forcing them to host inside Saudi Arabia was deleted in 2024 and replaced by a duty to ask a government office for a decision, and that office has published no replacement rule.
Does this apply to me?: Yes. The law reaches a company anywhere in the world with no office in Saudi Arabia, as long as it handles the data of people living in the Kingdom. There is no size, revenue or headcount threshold to fall below. There is no general duty to appoint a local representative, but many organisations must register on the government's data platform and some must name a data protection officer.High confidence
Can the data leave the country?: Yes, with real paperwork. First the reason for sending it has to be on the government's short list of allowed purposes. Then you need a safeguard: the government's own standard contract, approved group-wide rules, or a certificate from a licensed body. Then you must write a risk assessment that includes whether the transfer could damage the Kingdom's vital interests. Two industries are much harder. Banks and finance companies must get the central bank's written no-objection before any data goes to an overseas supplier, and the central bank's rules say cloud services should sit inside Saudi Arabia unless it approves otherwise. For government bodies and critical national infrastructure the picture changed in 2024 and is now genuinely unclear.High confidence
What do I have to do to send it abroad?: The model is an approved-destination list, and the list is empty. The law says data may go to a country the regulator has judged good enough, but no such list has been published, so in practice nobody uses that route. Instead almost everyone relies on the escape hatches: sign the government's word-for-word standard contract, or get approved group-wide rules for a multinational, or send to a body holding a certificate from a licensed Saudi accreditation body. On top of that you must run a written risk assessment before the data moves.High confidence
Who enforces this — and are they actually working?: The Saudi Data and Artificial Intelligence Authority is the privacy regulator, and it is genuinely up and running. Its National Data Governance Platform is live and takes registrations, self-assessments, breach reports and complaints, and it has published the rulebook for the panels that hear violations and issue fines. What we could not find is a single published fine or named decision, so how hard it bites is still unknown. The financial regulator and the cybersecurity authority, by contrast, have supervised their sectors for years.Medium confidence
How long must I keep it, and when must I delete it?: Both directions apply, and the floor wins when they clash. The ceiling: you must destroy personal data without undue delay once the reason you collected it has gone, and also when someone asks, when they withdraw the only consent you relied on, or when you learn you processed it unlawfully. Destruction must reach backups too. The floor: your written record of processing activities must be kept for five years after the activity ends. If another law sets a keeping period, the law says keep the data until whichever is longer.High confidence
What happens when something goes wrong?: The main clock is 72 hours. If personal data is breached, lost or accessed unlawfully and that could harm the people involved, you must tell the privacy regulator within 72 hours of finding out, through the government's data platform — and you have to be registered on that platform before you can use the service. You must also tell the affected people without undue delay, in plain language. A second, separate clock runs for government bodies and critical national infrastructure, which owe cyber incident reports to the national cybersecurity authority under its own rules. Suppliers owe you notice without undue delay so you can meet your own deadline.High confidence
What's the trap?: Five things that are not in the summary. One: sending data abroad is not only about protecting the individual — you must also assess whether the transfer could harm the Kingdom's own vital interests, and there is a government guide telling you how. Two: the standard contract must be copied word for word, and changing it is itself a breach of the law, while the overseas recipient has to accept Saudi courts. Three: leaking or publishing sensitive data to hurt someone or to profit can put a person in prison for up to two years — this is a criminal charge, not a fine. Four: your supplier contract must go beyond a normal data processing agreement and say whether the supplier is subject to foreign laws and how that affects its compliance. Five: the widely quoted rule that all government and critical infrastructure data must be hosted inside Saudi Arabia was deleted in 2024, and quoting it today is wrong.High confidence
What's about to change?: Nothing is scheduled to commence on a fixed date in the next twelve months — the law and all its main regulations are already fully in force. The risk is the opposite kind: several switches the government already holds and can flip with no consultation. The biggest is the approved-country list, which the regulator is legally required to publish and has not; the day it appears, every transfer plan in the country needs rechecking. The second biggest is the missing localisation rule for government and critical infrastructure, which one office was handed in 2024 and has not yet written.Medium confidence
Hardest industry wall: None found.

The eight framework questions answered for each selected country
Question	TurkeyChecked 18 August 2026	Saudi ArabiaChecked 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.	Data can leave Saudi Arabia, but never for free. You need a purpose the law allows, a written safeguard such as the government's own standard contract, and a written risk assessment that asks whether the transfer could harm the Kingdom itself. Banks need the central bank's written permission before anything goes abroad. The privacy regulator is fully set up but publishes no fines.
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.	The 'paperwork and you can send it' answer is true for an ordinary business. It is false for banks and finance companies, where the central bank must give written no-objection first and cloud is expected to sit inside the country. It is also unsettled for government bodies and critical national infrastructure: the old rule forcing them to host inside Saudi Arabia was deleted in 2024 and replaced by a duty to ask a government office for a decision, and that office has published no replacement rule.
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 reaches a company anywhere in the world with no office in Saudi Arabia, as long as it handles the data of people living in the Kingdom. There is no size, revenue or headcount threshold to fall below. There is no general duty to appoint a local representative, but many organisations must register on the government's data platform and some must name a data protection officer.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 real paperwork. First the reason for sending it has to be on the government's short list of allowed purposes. Then you need a safeguard: the government's own standard contract, approved group-wide rules, or a certificate from a licensed body. Then you must write a risk assessment that includes whether the transfer could damage the Kingdom's vital interests. Two industries are much harder. Banks and finance companies must get the central bank's written no-objection before any data goes to an overseas supplier, and the central bank's rules say cloud services should sit inside Saudi Arabia unless it approves otherwise. For government bodies and critical national infrastructure the picture changed in 2024 and is now genuinely unclear.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-destination list, and the list is empty. The law says data may go to a country the regulator has judged good enough, but no such list has been published, so in practice nobody uses that route. Instead almost everyone relies on the escape hatches: sign the government's word-for-word standard contract, or get approved group-wide rules for a multinational, or send to a body holding a certificate from a licensed Saudi accreditation body. On top of that you must run a written risk assessment before the data moves.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 Saudi Data and Artificial Intelligence Authority is the privacy regulator, and it is genuinely up and running. Its National Data Governance Platform is live and takes registrations, self-assessments, breach reports and complaints, and it has published the rulebook for the panels that hear violations and issue fines. What we could not find is a single published fine or named decision, so how hard it bites is still unknown. The financial regulator and the cybersecurity authority, by contrast, have supervised their sectors for years.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	Both directions apply, and the floor wins when they clash. The ceiling: you must destroy personal data without undue delay once the reason you collected it has gone, and also when someone asks, when they withdraw the only consent you relied on, or when you learn you processed it unlawfully. Destruction must reach backups too. The floor: your written record of processing activities must be kept for five years after the activity ends. If another law sets a keeping period, the law says keep the data until whichever is longer.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	The main clock is 72 hours. If personal data is breached, lost or accessed unlawfully and that could harm the people involved, you must tell the privacy regulator within 72 hours of finding out, through the government's data platform — and you have to be registered on that platform before you can use the service. You must also tell the affected people without undue delay, in plain language. A second, separate clock runs for government bodies and critical national infrastructure, which owe cyber incident reports to the national cybersecurity authority under its own rules. Suppliers owe you notice without undue delay so you can meet your own deadline.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 things that are not in the summary. One: sending data abroad is not only about protecting the individual — you must also assess whether the transfer could harm the Kingdom's own vital interests, and there is a government guide telling you how. Two: the standard contract must be copied word for word, and changing it is itself a breach of the law, while the overseas recipient has to accept Saudi courts. Three: leaking or publishing sensitive data to hurt someone or to profit can put a person in prison for up to two years — this is a criminal charge, not a fine. Four: your supplier contract must go beyond a normal data processing agreement and say whether the supplier is subject to foreign laws and how that affects its compliance. Five: the widely quoted rule that all government and critical infrastructure data must be hosted inside Saudi Arabia was deleted in 2024, and quoting it today is wrong.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	Nothing is scheduled to commence on a fixed date in the next twelve months — the law and all its main regulations are already fully in force. The risk is the opposite kind: several switches the government already holds and can flip with no consultation. The biggest is the approved-country list, which the regulator is legally required to publish and has not; the day it appears, every transfer plan in the country needs rechecking. The second biggest is the missing localisation rule for government and critical infrastructure, which one office was handed in 2024 and has not yet written.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	None found.