Data Processor
"What is the difference between data controller and processor under Turkish law?"
Quick Answer
Under KVKK, data processors process personal data on the controller’s behalf and instructions. They must implement appropriate technical and organisational security measures.
Scope and Legal Distinctions
A processor handles personal data on behalf of a controller. A service provider determining its own purposes may be a controller for some processing, even if called a processor in the contract.
What to Check in Practice
Map each operation, instructions and independent uses; allocate security and notification responsibilities and check any cross-border transfer route.
Sources & Authorities
Statutory framework and official guidance for this definition.
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