KVKK Compliance Checklist
Does Your Company Need a Data Controller Representative in Türkiye?
Under the Turkish Data Protection Law (KVKK), foreign data controllers who process the personal data of data subjects residing in Türkiye are mandated to appoint a Data Controller Representative (Veri Sorumlusu Temsilcisi).
Use this strategic check-list to determine your company’s legal obligations:
Section 1: Jurisdictional Scope
Is your company established/headquartered outside of Türkiye?
Does your company process personal data belonging to individuals located in Türkiye?
Do you offer goods or services (even if free of charge) to data subjects in Türkiye?
Do you monitor the behavior of individuals located within Turkish territory?
Section 2: VERBIS Registration Requirements
Is your company currently registered with the Data Controllers’ Registry (VERBIS)?
Have you officially appointed a legal entity or a Turkish citizen resident in Türkiye as your representative?
Does your representative have the authority to facilitate communication with the KVKK Board?
How to Interpret Your Results
If you answered "YES" to all questions in Section 1 and "NO" to Section 2: Your company is likely in breach of Article 11 of the Regulation on the Data Controllers’ Registry. Foreign data controllers are required to appoint a representative regardless of the number of employees or annual turnover.
Next Steps & Professional Inquiry
For a technical evaluation of your company’s specific data processing activities and to ensure alignment with the latest KVKK Board resolutions, please refer to our Contact Page or communicate with our office via official corporate channels.