KVKK Compliance
GlobalB Law guides Turkish and international businesses through full compliance with the Turkish Personal Data Protection Law (KVKK), including registration, policy frameworks and engagement with the Personal Data Protection Authority (KVKK Kurumu).
Türkiye's KVKK shares its conceptual DNA with the GDPR but operates under a distinct regulatory regime administered by the Personal Data Protection Authority (KVKK Kurumu). Every data controller established in Türkiye, and many foreign controllers that target Turkish users, must register with the VERBİS system, maintain a lawful basis for each processing activity, and comply with strict rules on data subject rights, consent and cross-border transfers. Sanctions have tightened progressively, and the Authority has become more assertive in its sector-specific investigations.
GlobalB Law has deep familiarity with the Turkish regulatory landscape. We advise clients through the full compliance lifecycle: VERBİS registration, internal policy architecture, data subject rights procedures and vendor agreements tailored to the Turkish framework. For international companies entering the Turkish market, we align KVKK requirements with an existing GDPR programme to avoid duplication and catch the gaps that a GDPR-only lens inevitably misses.
Key Differences From GDPR That We Address
- VERBİS registration, mandatory for data controllers above prescribed thresholds; foreign controllers who process Turkish residents' data must also register
- Explicit consent requirements. KVKK's consent standard is narrower and less flexible than GDPR's legitimate-interests basis
- Cross-border transfer restrictions. Türkiye requires either explicit consent or adequacy finding / safeguard for each transfer; the regime is currently in transition following 2024 amendments
- Data breach notification, must be filed with the Authority within 72 hours of detection
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FAQ
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Our company is based in Germany but collects data from Turkish users through our app. Do we need to comply with KVKK?
Yes. KVKK applies to foreign data controllers that process personal data of individuals in Türkiye through automated means, or that offer goods or services targeting Türkiye. You must typically register with VERBİS and comply with Turkish consent and transfer rules, which differ materially from the GDPR framework you may already have in place.
What is VERBİS and do all companies need to register?
VERBİS (Veri Sorumluları Sicil Bilgi Sistemi) is the Turkish data controllers' registry. Registration is mandatory for controllers above certain employee and financial thresholds set by the Authority, and for all public legal entities. Foreign controllers who process Turkish residents' data must also register regardless of size. Failure to register is a specific sanctionable offence under KVKK.
We are already GDPR-compliant. How much extra work does KVKK require?
A GDPR programme provides a strong foundation, but KVKK has meaningful divergences: it does not recognise legitimate interests as a lawful basis in the same way, has specific VERBİS registration obligations, applies stricter rules on cross-border transfers, and requires explicit consent in contexts where GDPR would allow other bases. Our standard approach is a gap analysis that layers KVKK requirements on top of your existing GDPR documentation, minimising duplication.
What are the penalties for KVKK non-compliance?
Administrative fines under KVKK range from tens of thousands to millions of Turkish lira depending on the violation category, and the Authority regularly publishes sanction decisions. Beyond fines, criminal liability provisions in the Turkish Penal Code apply to certain data offences, a dimension GDPR does not directly replicate. Enforcement activity has increased significantly in recent years across the tech, healthcare and financial sectors.
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