KVKK transfer By-Law Article 16: an occasional transfer is one that is not regular and not part of ordinary business, and may rest on informed explicit consent (By-Law on the Procedures and Principles for the Transfer of Personal Data Abroad, Official Gazette 10 July 2024, No. 32598 (KVKK courtesy translation, the Turkish text prevails), Art. 16(1) and (2)(a))
Without an adequacy decision or a signed safeguard, the only route is explicit consent after being told the risks, and only for a transfer that is not regular, happens once or a few times and is not part of ordinary business. A one-off licence can qualify; a holder that licenses its records to many buyers or on a continuing basis cannot rely on it.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“Transfers that are not regular, occur only once or a few times, do not have a continues nature, and are not part of the ordinary course of business shall be considered incidental. ... a) The data subject has given explicit consent to the transfer, provided that he/she has been informed of the potential risks involved;”
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