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Every foreign company operating in Korea moves Korean personal data across a border. A global HR system, a cloud CRM, a group data warehouse, a support team in another time zone with read access to Korean customer records — each of these is a cross-border transfer under Korean law, and each requires a legal basis. As of 11 September 2026, getting this wrong costs considerably more than it did. What counts as a transfer is broader than you think The Personal Information Protec