Pursuant to Article 16 paragraph (2) of the Law on the Protection of the Personal Data No. 6698, real and legal persons who process personal data shall be registered to the Registry of Data Controllers ("Registry").
From 1 October 2018 the registration obligation of the real and legal person data controllers ("Data Controllers") that are stated below has been started:
- Data Controllers who employ more than 50 employees in a year or whose total annual financial statement is more than 25 million Turkish Lira must be registered to the Registry between 01.10.2018 and 30.09.2019.
- Non-resident Data Controllers must be registered to the Registry between 01.10.2018 and 30.09.2019.
- Data Controllers who process special categories of personal data as the main activity must be registered to the Registry between 01.10.2019 and 03.2020 even if they employ less than 50 employees in a year, and their total annual financial statement is less than 25 million Turkish Lira.
The registration obligation of the Data Controllers who are qualified as public institutions and organizations will take its start on 1 April 2019 and shall be completed by 30 June 2020.
The registration shall be done through Data Controller Registry Information System ("VERBIS") and VERBIS is accessed from the www.kvkk.gov.tr web-site. VERBIS icon is placed on the right side of the home page.
In order to register, first, the Data Controller shall be confirmed. Accordingly, a standard notification form which introduces the Data Controller shall be filled out. The appointed contact person shall be registered and following that step, the appointed contact person shall complete the registration process.
The data to be notified shall be registered under the categories that have been determined by VERBIS. Then the data processing objectives, recipient groups, data storage periods, data subject person groups, data to be transferred to foreign countries and the data safety measures shall be registered.
Please find the VERBIS Guideline here for detailed information.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.