KVKK Compliance in Turkey — Key Facts
Turkish data protection law is built around Law No. 6698 on the Protection of Personal Data — KVKK. The Personal Data Protection Authority and Board enforce the framework through registry obligations, information and security duties, transfer rules, decisions and administrative fines.
2026 KVKK Snapshot
2024 Article 6 and 9 reformSpecial-category processing and cross-border transfer rules materially changed.
Cross-border transfersUse adequacy decisions, appropriate safeguards or limited incidental-transfer circumstances where statutory conditions are met.
Turkish standard contractsFour Board templates: Controller → Controller, Controller → Processor, Processor → Processor and Processor → Controller.
Five-business-day notificationExecuted standard contracts must be notified to the Authority within five business days.
VERBİS ordinary local exemptionGenerally below 50 employees and below TRY 100 million annual balance-sheet total, where the other conditions are satisfied.
Special-category exemptionUnder Decision No. 2025/1572, qualifying controllers may be exempt below 10 employees and below TRY 10 million balance sheet.
Notice and consentDecision No. 2026/347 requires separate structuring where processing relies on explicit consent.
Biometric attendanceDecision No. 2026/921 materially changes the risk analysis for biometric data used solely for employee attendance.
Last legal review: September 2026. Thresholds, Board decisions and fine ranges should be reviewed whenever the Authority issues an update.
1. KVKK Gap Analysis for International Businesses
Compliance should begin with actual data flows rather than a folder of template policies. We review websites, apps, CRM, customer onboarding, sales, marketing, HR, recruitment, payroll, CCTV, access control, IT, cloud services, finance, support, suppliers, logistics, group-company systems, analytics, cookies, AI tools and security operations.
The review asks what data is collected, who is the controller, which Article 5 or Article 6 condition applies, whether special-category data is involved, which systems and vendors receive it, whether it leaves Turkey, how long it is retained, whether deletion is implemented, whether VERBİS reflects reality and whether the company can prove its position.
Deliverable: risk-ranked KVKK gap report
Critical, high, medium and low findings with required remediation, responsible workstreams and implementation priority.
Request a KVKK gap analysis 2. GDPR to KVKK Localisation
GDPR compliance is a strong starting point, not a substitute for Turkish legal analysis. We classify the existing programme into three tracks:
KEEP
Existing global controls and governance that can remain effective in Turkey.
- Global accountability framework
- Security and governance standards
- Group-wide retention principles
LOCALISE
Documents and processes that require Turkish adjustments.
- Controller identity and notices
- Legal bases and consent language
- VERBİS and representation
REBUILD
Mechanisms that do not work under the current KVKK framework.
- Article 9 transfer route
- Turkish standard-contract pack
- Incident and authority response
DELIVER
A Turkey-specific privacy pack aligned with actual operations.
- Localisation matrix
- Priority remediation plan
- Evidence-ready implementation
An EU SCC does not automatically satisfy the Turkish Article 9 transfer mechanism. Localise our GDPR programme.
3. Personal Data Inventory & Data Mapping
A reliable privacy programme depends on knowing what the organisation actually processes. We map the business process, data subject group, data category, special-category data, purpose, legal basis, collection method, storage location, domestic and foreign recipients, retention period, technical measures, administrative measures and controller / processor role.
The inventory should remain consistent with VERBİS, privacy notices, consent flows, retention policy, vendor agreements and cross-border transfer documents. We can build, update or quality-check the inventory so it works as an operational control rather than a static spreadsheet.
Build or update the data inventory
4. VERBİS Registration & Foreign Data Controller Representation
VERBİS is the Turkish Data Controllers’ Registry Information System. Registration is the public-facing output of a wider data-mapping exercise, not an isolated portal form. We advise on whether registration is required, applicable exemptions, employee and balance-sheet thresholds, principal activity, special-category processing, foreign-controller status, representative structure, registry categories, updates and compliance evidence.
Local controllers
For an ordinary local controller whose principal activity is not special-category processing, the general exemption generally requires both fewer than 50 annual employees and less than TRY 100 million annual balance-sheet total.
Special-category activity
Decision No. 2025/1572 introduced a separate qualifying exemption where employees are fewer than 10 and the annual balance-sheet total is below TRY 10 million.
Foreign controllers
Non-resident controllers should be assessed separately. Local employee and balance-sheet exemptions should not be assumed to apply automatically.
Representation
Where the applicable framework requires a Turkish compliance contact, we advise on appointment, mandate, VERBİS, Authority communications and data-subject correspondence.
Check VERBİS and foreign-controller status
5. Privacy Notices, Transparency & Explicit Consent
We draft and review KVKK privacy notices and clarification texts for websites, e-commerce, mobile applications, customers, prospects, employees, candidates, CCTV, visitors, suppliers, business contacts, call centres, loyalty programmes, events and campaigns. A compliant notice should accurately address controller identity, processing purposes, recipients or transfers, collection method, legal basis and data-subject rights.
Decision No. 2026/347: notice and consent are separate
Where consent is required, the privacy notice should not be treated as something the individual “consents to”. The privacy information / clarification text and explicit-consent text should be structured separately.
Explicit consent is one lawful processing condition, not a catch-all. We test whether consent is actually required, whether it is specific and freely given, whether purposes are bundled, whether withdrawal works and whether the record can be proved.
We also review employee, health, biometric, loyalty, profiling, marketing, cross-border and mobile-app consent flows. Review privacy notices or consent flows.
6. Special Category Data, Employee Privacy & Biometrics
KVKK Article 6 regulates special categories such as health, biometric, genetic, criminal conviction, religion, philosophical belief, political opinion, association / foundation / union membership, appearance or clothing-related protected information and sexual life. We advise on the correct Article 6 condition, employment processing, access controls, encryption, transfer, retention and additional technical or administrative safeguards.
Employee privacy work covers recruitment, HR, payroll, bank, performance, disciplinary, CCTV, access control, health, disability, background checks, monitoring, email and device use, remote work, global HR systems, payroll vendors, cross-border transfers and retention after termination. Employment imbalance means consent should not be assumed to be the safest basis merely because a signature can be obtained.
Biometric attendance after Decision No. 2026/921
The decision concerns biometric data used solely for employee attendance tracking and points businesses toward less intrusive alternatives such as cards, PINs, RFID / NFC access cards or conventional signatures. Other biometric uses must still be assessed separately by purpose, necessity, legal basis and proportionality.
Assess a biometric system 7. Cross-Border Personal Data Transfers From Turkey
Turkish data may need to move to global or regional headquarters, cloud infrastructure, SaaS providers, CRM vendors, payroll and HR platforms, security providers, analytics tools, customer-support systems, group companies or external advisers. The 2024 Article 9 reform introduced a staged analysis:
- Check adequacy: assess whether the destination, sector or international organisation benefits from an applicable adequacy decision.
- Identify an appropriate safeguard: consider Turkish standard contracts, binding corporate rules, qualifying public-sector arrangements or written undertakings approved by the Board.
- Use incidental grounds carefully: limited exceptions should not become a routine operating model.
We map the exporting entity, recipient role, destination, domestic legal basis, Article 9 mechanism, onward transfers, processor chain, cloud architecture, special-category data, safeguards, evidence and regulator notification.
Map cross-border data transfers
8. Turkish Standard Contracts & Binding Corporate Rules
For many international businesses, the Turkish standard contract is the most practical Article 9 safeguard. The Board publishes four templates: Controller → Controller, Controller → Processor, Processor → Processor and Processor → Controller. Selection depends on the actual role of each party, not the label used in a global template.
We assist with role analysis, template selection, annex completion, data categories, data subjects, purposes, recipient groups, technical safeguards, special-category safeguards, onward transfers and the five-business-day notification.
July 2026 execution practice
The Authority announcement highlights signatures by authorised persons, signature on the Turkish text, supporting authority documents and authentication or notarised Turkish translation requirements for foreign documents. Amendment limits and the notification file should be checked before signature.
For group transfers, we assess whether binding corporate rules are appropriate, prepare the application structure and align the internal framework with the actual entities, transfers and data-subject rights.
9. Vendor Contracts, Cookies, Marketing & Retention
Vendor contracts and DPAs
We review controller / processor roles, data processing agreements, security measures, sub-processors, audit rights, deletion, incident escalation and international transfer clauses. Labels must match reality.
Cookie compliance
We assess strictly necessary, analytics, tracking and marketing cookies against the actual processing basis. Where no other statutory condition applies, non-essential cookies should rely on valid prior opt-in consent.
Marketing and CRM
We review lead collection, campaign permissions, profiling, IYS interaction, purchased or referred contact data and the Authority’s 2026 warning on third-party data for advertising and marketing.
Retention and destruction
We align retention periods, deletion triggers, destruction records, backups, legal holds and notices with the inventory, statutory duties, contractual needs and actual system capability.
10. Data-Subject Requests, Security & Governance
We design request intake and response workflows for access, correction, deletion, objection and other data-subject rights, including identity checks, deadline tracking, system searches, exemptions, response drafting and evidence.
We advise on technical and administrative measures from a legal governance perspective: policies, access controls, vendor oversight, training, incident escalation, inventory alignment, risk registers and Board-ready evidence. We do not present legal counsel as a substitute for qualified penetration testing or technical security services.
11. Data Breach Response, Board Investigations & Defence
When a breach occurs, the legal response must run alongside containment and forensic work. We help structure the first response, identify affected data and special categories, assess the controller and processor roles, coordinate the notification record, assess data-subject communication and preserve evidence.
The 72-hour point must be described accurately
KVKK Article 12 requires notification “as soon as possible”. Board Decision No. 2019/10 interprets notification to the Board as no later than 72 hours after awareness. The 72-hour formulation should not be presented as the literal wording of Article 12.
For a Board investigation or information request, we align the response with the inventory, notices, VERBİS, contracts, actual processing, security measures and remediation plan. We can support authority correspondence, data-subject communications, internal governance and the defence record.
12. 2026 KVKK Administrative Fine Ranges
Fine exposure depends on the obligation, facts and enforcement decision. The following ranges are included for planning and should not be read as a prediction of any outcome.
Information obligationTRY 85,437 – TRY 1,709,200
Data-security obligationsTRY 256,357 – TRY 17,092,242
Failure to comply with Board decisionsTRY 427,263 – TRY 17,092,242
VERBİS registration / notificationTRY 341,809 – TRY 17,092,242
Standard-contract notification under Article 9(5)TRY 90,308 – TRY 1,806,177
13. Privacy Due Diligence, Ongoing Counsel & Deliverables
For M&A, investment, vendor onboarding and market entry, we test the privacy position that will transfer with the business: notices, consent, inventory, VERBİS, representation, transfers, contracts, incidents, data-subject requests, security governance, open authority correspondence and remediation cost.
Assessment
Risk-ranked gap analysis, data map, VERBİS / representation position and transfer matrix.
Documents
Turkey privacy pack: notices, consent, inventory, retention, vendor, transfer and incident documents.
Implementation
Prioritised remediation plan, ownership, deadlines, system changes and evidence checklist.
Continuity
Ongoing counsel for new vendors, products, campaigns, employees, incidents and Authority contact.
Send us the company or group structure, Turkish entity if any, current VERBİS status, main data categories, employee count, relevant balance-sheet threshold, major systems and cloud providers, countries receiving Turkish data, existing GDPR documents and the immediate concern.
14. Why Businesses Use Turkish Trade Lawyers for KVKK Matters
Operational privacy, not template compliance: we connect documents to data flows, systems and decisions.
GDPR-to-KVKK translation: we preserve workable global controls and identify the Turkish delta.
Cross-border transfer capability: we assess roles, Turkish standard contracts, BCRs, notification and evidence.
Commercial integration: privacy work is aligned with employment, commercial contracts, technology, corporate structuring and incident response.
Current regulatory position: the service reflects the 2025/1572 VERBİS exemption, 2026/347 notice-and-consent decision, 2026/921 biometric attendance decision, July 2026 standard-contract guidance and 2026 fine ranges.
Frequently Asked Questions About KVKK and Data Protection in Turkey
What is KVKK?
KVKK is Law No. 6698 on the Protection of Personal Data, the principal Turkish framework governing personal-data processing, data-controller duties, data-subject rights, registry obligations, transfers and security.
Is KVKK the same as GDPR?
No. The frameworks share concepts, but Turkish legal bases, notices, consent architecture, VERBİS, Article 9 transfers and local regulator practice require a Turkey-specific analysis.
Does every Turkish company need to register with VERBİS?
No. Exemptions and thresholds apply in some cases, and foreign-controller status must be assessed separately. The ordinary local exemption generally requires both the employee and balance-sheet conditions to be satisfied.
Can explicit consent be used for every processing activity?
No. The correct Article 5 or Article 6 condition should be identified for each purpose. Unnecessary consent can obscure the real legal basis and create operational risk.
Can we modify the Board’s Turkish standard contract?
The Board’s current practice and guidance should be checked before signature. The parties should preserve the required structure, complete the annexes accurately and assess any proposed amendment with care.
Do strictly necessary cookies require explicit consent?
Not automatically. The actual purpose and applicable statutory processing condition must be assessed. Non-essential cookies should rely on valid prior opt-in consent where no other lawful basis applies.
How long do we have to answer a data-subject request?
The request should be handled within the statutory response framework, with identity, scope, applicable exemptions and evidence tracked. We can design the intake and response workflow.
Can Turkish Trade Lawyers respond to a KVKK Authority letter?
Yes. We can review the request, map it to the actual processing and evidence, coordinate the response and support the remediation record.
Can you review our website for KVKK compliance?
Yes. We can review notices, consent flows, cookies, forms, analytics, marketing, vendors, transfers, retention and the connection between the public-facing materials and the internal inventory.
Can you perform a GDPR-to-KVKK gap analysis?
Yes. We compare the global programme against Turkish requirements and deliver a keep / localise / rebuild matrix with prioritised remediation.
Official Sources & Authority Materials
The page’s legal positioning is based on the Personal Data Protection Authority’s published materials. These links should be checked again when the Authority issues a new decision, threshold or fine table.