The Personal Data Protection Authority's ("Authority") Resolution on Exemptions of Registration to the Data Controllers' Registry dated 02.04.2018 and numbered 2018/32 was published in the Official Gazette dated 15.05.2018 and numbered 30422. According to the Resolution, the following persons are exempt from the registration requirement:
- Personal data processors that process such data otherwise than by automatic means which form part of a filing system,
- Notaries operating in accordance with the Notary Public Law dated 18.01.1972 and numbered 1512,
- Associations established in accordance with the Law on Associations dated 04.11.2004 and numbered 5253, foundations established in accordance with the Law on Foundations dated 29.02.2008 and numbered 5737, and trade unions established in accordance with the Law on Trade Unions and Collective Labor Agreements dated 18.10.2012 and numbered 6356 who only process personal data limited to the areas of activity appropriate to the relevant legislation and its purposes and only the personal data of its employees, members, relatives and donors,
- Political parties established in accordance with the Law on Political Parties dated 22.04.1983 and numbered 2820,
- Attorneys working in accordance with the Law on Attorneyship dated 19.03.1969 and numbered 1136,
- Certified public accountants and sworn-in certified public accountants working in accordance with the Law on Certified Public Accountants and Sworn-in Certified Public Accountants dated 01.06.1989 and numbered 3568.
In addition to this development, the Authority published an announcement regarding the Minimum Components of the Letter of Undertaking to be Prepared by Data Controllers while Transferring Data Abroad ("Announcement") on their website on 16.05.2018.
Moreover, the Authority has published two different drafts of letter of undertaking; the first draft being applicable for the data transfer between Data Controllers and the second draft being applicable for the data transfer from Data Controller to Data Processor.
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.