# KVKK — CROSS-BORDER TRANSFER DECISION RECORD

Document code: TR-KVKK-09 · Version 1.0 · Classification: Internal
Organisation: [NAME]   Prepared by: [NAME/ROLE]   Date: ……/……/20……
Reference: KVKK Art. 9 (amended by Law 7499; regime from 1 June 2024)

SECTION 1 — TRANSFER DESCRIPTION
Data categories: [……]   Special category? [ ] Y [ ] N
Data subjects: [……]   Purpose: [……]
Recipient / importer: [NAME]   Country: [……]
Repetitive or one-off? [ ] recurring  [ ] incidental

SECTION 2 — ROUTE SELECTION  (choose one, in order)
[ ] 1. Adequacy decision covers this destination — reference: ……
[ ] 2. Appropriate safeguard:
       [ ] Standard contract (Board form) — signed ……, notified to Board on ……
           (deadline: 5 business days from signature)
       [ ] Binding corporate rules — Board approval ref: ……
       [ ] International agreement (public bodies) — ref: ……
       [ ] Written undertaking — Board authorisation ref: ……
[ ] 3. Exceptional case (incidental only):
       [ ] explicit consent [ ] contract [ ] legal claim [ ] vital interest
       [ ] other: ……   — basis this is NOT recurring: ……

SECTION 3 — GENERAL COMPLIANCE
[ ] Article 4 principles met (purpose limitation, minimisation, accuracy)
[ ] Privacy notice covers the transfer
[ ] VERBİS registration current
[ ] Security measures appropriate (Art. 12)

SECTION 4 — RECORDS
Retain the signed instrument, Board notification/approval evidence and this
decision record.

Owner: [ROLE]   Review cycle: [PERIOD]   Next review: ……/……/20……

This template is general and does not constitute legal advice.