Sending personal data from Andorra to engineers in Türkiye
Llei 29/2021 (the LQPD) has been in force since 17 May 2022 and is supervised by the Agència Andorrana de Protecció de Dades (APDA). Under its Articles 43 and 44, no extra safeguards are needed for transfers to EU member states, to countries, territories or sectors on the EU adequacy list, or to countries effectively bound by Council of Europe Convention 108+. Türkiye falls outside the first two. Other transfers, for example to a development or hosting vendor elsewhere, need adequate safeguards such as binding corporate rules or standard data protection clauses adopted by the European Commission or by the APDA, unless an Article 45 exception applies, such as the person's explicit, informed consent. Whether the Convention 108+ route covers Türkiye is worth confirming with a lawyer. In practice, clauses can be signed before access is granted, development can run on seeded test data and production access can stay narrow.





