According to the decision of the Turkish Personal Data Protection Authority ("KVKK") dated 2020/482 numbered 23.06.2020, the deadlines for registration obligation to Data Controllers' Registry Information System ("VERBIS") have been extended.

With the relevant decision, it has been concluded that,

  • For natural and legal person data controllers with more than 50 employees annually or a financial balance of more than 25 million TL annually, the deadline for fulfilling VERBIS registration and declaration obligation to Registry to be extended to 30.09.2020,
  • For natural and legal person data controllers resident abroad, the deadline for fulfilling VERBIS registration and declaration obligation to Registry to be extended to 30.09.2020,
  • For natural and legal person data controllers with less than 50 employees annually and a financial balance of less than 25 million TL annually, and whose main activity is sensitive personal data processing, the deadline for fulfilling VERBIS registration and declaration obligation to Registry to be extended to 31.03.2021,
  • For public institutions and organizations the deadline for fulfilling VERBIS registration and declaration obligation to Registry to be extended to 31.03.2021,

and this decision to be announced at the website of the Authority and to be published in the Official Gazette.

We would like to emphasize that the relevant decision did not bring any changes about the compliance with the Law No. 6698 on the Protection of Personal Data ("KVKK") other than the registration deadline to VERBIS.

In order to protect the fundamental rights and freedoms of individuals, especially the privacy of individuals, natural and legal persons who process personal data are required to complete the compliance processes related to their administrative and technical obligations in processing personal data.

Current Deadlines Provided By The Authority For VERBIS Registration

Data Controllers Start Date of Registration Obligation Period of Time Given for Registration Deadline for Registration

Natural and legal person data controllers with an annual number of employees of more than 50 or annual financial balance of more than 25 million TL

 01.10.2018 24 months 30.09.2020

Natural and legal person data controllers resident abroad

 01.10.2018 24 months 30.09.2020

Natural and legal person data controllers with an annual number of employees of less than 50 or annual financial balance of less than 25 million TL and whose main activity is sensitive personal data processing

 01.01.2019 27 months 31.03.2021

Public institutions and organizations

 01.04.2019 24 months 31.03.2021

Originally Published by Cott Group, June 2020

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