Turkey: Veri Sorumluları Siciline Kayıt Yükümlülüğü: Zorunlu Kayıt Tarihleri Ve İstisnalar

Last Updated: 3 September 2018
Article by Abdulkadir Guzeloglu and Tarik Kurban

6698 sayili Kisisel Verilerin Korunmasi Kanunu'nun ("KVKK") 16'inci maddesi ile Kisisel verileri isleyen gerçek ve tüzel kisiler için, veri islemeye baslamadan önce Veri Sorumlulari Siciline ("VERBIS") kayit olma yükümlülügü getirilmektedir.

KVKK'nin 16'inci maddenin ikinci fikrasi, Kisisel Verileri Koruma Kurumu'nun ("Kurum") VERBIS'e kayit yükümlülügü hakkinda islenen kisisel verinin niteligi, sayisi, veri islemenin kanundan kaynaklanmasi veya üçüncü kisilere aktarilma durumu gibi Kurumca belirlenecek objektif kriterler göz önüne alinmak suretiyle istisna getirilebilecegini belirtmektedir.

VERBIS'e kayit yükümlülügü ve bu yükümlülüge getirilecek olan istisnalarin kriterleri Veri Sorumlulari Sicili Hakkinda Yönetmelik tarafindan ayrintili olarak düzenlenmistir. Ilgili yönetmelik ile ilgili yaziya bu baglanti ile ulasabilirsiniz: Kisisel Verileri Koruma Kurumu tarafindan hazirlanan Veri Sorumlulari Sicili Hakkinda Yönetmelik 30 Aralik Cumartesi günü Resmi Gazetede yayimlandi

Kanunun ilgili maddesi ve yönetmelik uyarinca Kurum'un 15.05.2018 tarihli Resmî Gazete'de yayimlanan 2018/32 sayili karari uyarinca VERBIS' kayit yükümlülügüne getirilen istisnalar su sekildedir:

1. Herhangi bir veri kayit sisteminin parçasi olmak kaydiyla yalnizca otomatik olmayan yollarla kisisel veri isleyenler

2. 1512 sayili Noterlik Kanunu uyarinca faaliyet gösteren noterler

3. 5253 sayili Dernekler Kanunu'na göre kurulmus derneklerden, 5737 sayili Vakiflar Kanunu'na göre kurulmus vakiflardan ve 6356 sayili Sendikalar ve Toplu Is Sözlesmesi Kanunu'na göre kurulmus sendikalardan yalnizca ilgili mevzuat ve amaçlarina uygun, faaliyet alanlariyla sinirli ve sadece kendi çalisanlarina, üyelerine, mensuplarina ve bagisçilarina yönelik kisisel veri isleyenler

4. 2820 sayili Siyasi Partiler Kanunu'na göre kurulmus olan siyasi partiler

5. 1136 sayili Avukatlik Kanunu uyarinca faaliyet gösteren avukatlar

6. 3568 sayili Serbest Muhasebeci Mali Müsavirlik ve Yeminli Mali Müsavirlik Kanunu uyarinca faaliyet gösteren serbest ve yeminli mali müsavirler

Kurumun 18.08.2018 tarihli Resmî Gazete'de yayimlanan kararlari ile istisna kapsami genisletilmis. Buna göre asagida sayilanlar da istisna kapsamina alinmistir:

1. 4458 sayili Gümrük Kanunu uyarinca faaliyet gösteren Gümrük Müsavirleri ve Yetkilendirilmis Gümrük Müsavirleri

2. Arabulucular

3. Yillik çalisan sayisi 50'den az ve yillik mali bilanço toplami 25 milyon TL'den az olan gerçek veya tüzel kisi veri sorumlularindan ana faaliyet konusu özel nitelikli kisisel veri isleme olmayanlar

Sicile Kayit Yükümlülügünün Baslangiç Tarihleri

Kurum tarafindan yayimlanan 2018/88 sayili karar ile VERBIS'e kayit yükümlülügüne iliskin tarihle su sekilde belirlenmistir.

Veri Sorumlulari

Kayit Yükümlülügü Baslangici

Kayitlarin Tamamlanmasi Için Süre

Kayit Için Son Tarih

Yillik çalisan sayisi 50'den çok veya yillik mali bilanço toplami 25 milyon TL'den çok olan gerçek ve tüzel kisi veri sorumlulari


12 Ay


Yurtdisinda yerlesik gerçek ve tüzel kisi veri sorumlulari


12 Ay


Yillik çalisan sayisi 50'den az ve yillik mali bilanço toplami 25 milyon TL'den az olmakla birlikte ana faaliyet konusu özel nitelikli kisisel veri isleme olan gerçek ve tüzel kisi veri sorumlulari


15 Ay


Kamu kurum ve kurulusu veri sorumlulari için


15 Ay


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