On 25 June 2021, the Turkish Data Protection Board (the “Board”) announced its decision to narrow the exemption previously introduced for associations, foundations and unions concerning the obligation to register with the Data Controllers' Registry (“VERBIS”).
In general, natural and legal persons who process personal data must register with VERBIS. The Board is also entitled to apply exemptions to this obligation for specific data controllers. In this context, the Board had previously announced that associations, foundations and unions registered in Turkey are exempt from the obligation to register with VERBIS.
Following several written and verbal requests to the Board for an opinion on this issue, the Board re-evaluated its position and narrowed the VERBIS registration exemption for associations, foundations, and unions. In its latest decision, the Board states that associations, foundations and unions that also have a commercial enterprise are now excluded from this exemption.
As a result, associations, foundations and unions with a commercial enterprise are obliged to register with VERBIS by 31 December 2021. It is worth noting that such entities shall be responsible for notifying VERBIS of their data processing activities limited to their commercial purposes.
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.