Explicit consent survives in a limited form among the incidental cases; for continuous flows, however, an appropriate safeguard (such as the standard contract) is essential. Legacy consent-based arrangements should be reviewed.
The instrument depends on the flow: incidental, one-off transfers can still rest on explicit consent, but periodic or continuous flows need an appropriate safeguard — the KVKK standard contract, binding corporate rules, or an undertaking. The standard contract must be notified to the Authority within five business days of signing, so calendar that step into the rollout.
Shall we apply this matter to your situation?
Tell us your specific situation in a few sentences; we'll assess it with the right team.
This content is for general information only and does not constitute legal advice. Please contact our team for an assessment of your specific circumstances.
Categories