GDPR vs KVKK
"What are the main differences between GDPR and Turkish KVKK?"
Quick Answer
GDPR and Türkiye’s KVKK (Law No. 6698) share similar principles, but practical differences often arise around lawful bases and consent practices, VERBIS registration, timelines and procedure for data subject requests, cross-border data transfers, and how regulators enforce compliance.
GDPR vs KVKK: The Legal Framework
In Türkiye, personal data processing is regulated mainly by the Personal Data Protection Law No. 6698 (KVKK) and decisions/guidance of the Personal Data Protection Authority and Board. GDPR applies under EU law (including extraterritorial scope in certain cases). While the two regimes overlap in principles, businesses often face different compliance workflows and documentation expectations in practice.
Key Points to Remember
- Scope: GDPR can apply extraterritorially; KVKK primarily targets processing in Türkiye and certain Türkiye-linked processing activities.
- Legal bases: both recognize multiple grounds beyond consent, but consent and notice mechanics may be treated differently in practice.
- Controller obligations: KVKK may require VERBIS registration for eligible controllers; GDPR uses records/accountability without a VERBIS-style public registry.
- International transfers: both require a compliant transfer mechanism; the available routes and required documentation differ.
- Rights & workflow: both grant data subject rights, but request handling procedures and local expectations can vary.
Practical Implementation
Organizations should implement appropriate technical and organizational measures, keep an accurate data inventory (data mapping), publish compliant privacy notices, design lawful-basis/consent flows, and maintain an incident response plan (including any notification steps required under KVKK practice and Board decisions).
The Personal Data Protection Authority and Board enforce KVKK through decisions, investigations, and administrative fines. Because guidance and practice evolve, periodic compliance health checks and document updates are recommended—especially for cross-border transfers, vendor contracts, and security controls.
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