As is known, according to Article 16 of the Law on the Protection of the Personal Data No. 6698 (“Law”), real and legal persons who process personal data shall be registered to the Registry of Data Controllers (“Registry”).

The relevant dates for fulfilling the registration obligation was determined by Personal Data Protection Board (“Board”) according to provisional article 1 of the Law and was announced as follows:

  Data controllers Starting date Prescribed term Due date
1 Data controllers who employ more than 50 employees in one year or whose total annual financial balance sheet is more than 25 million Turkish Lira 01.10.2018 15 months 31.12.2019
2 Non-resident data controllers 01.10.2018 15 months 31.12.2019
3 Data controllers whose main activity is processing personal data of special nature as the main activity,and who employ less than 50 employees in one year, and whose total annual financial balance sheet is less than 25 million Turkish Lira 01.01.2019 15 months 31.03.2020
4 Data controllers who are qualified as public institutions and organizations 01.04.2019 15 months 30.06.2020

Pursuant to Board’s decision numbered 2019/387 and dated 27.12.2019, considering the data controllers who have randomly made the registration and notification to Data Controller Registry Information System (“VERBİS”) by not preparing the personal data inventory and whocannot fulfil their registration and notification obligation within the determined terms since they have not completed the process of the inventory preparation,in order to take the required actions to remedy any mistake or contradiction to the Law within the information submitted to VERBİS, if any, the terms are extended to the below-stated dates according to provisional article 1 of the Law numbered 6698;

  • Real and legal person data controllers who employ more than 50 employees in one year or whose total annual financial balance sheet is more than 25 million Turkish Lira must be registered to the Registry until 30.06.2020.
  • Real and legal person data controllers who are non-resident must be registered to the Registry until 30.06.2020.
  • Real and legal person data controllers whose main activity is processing personal data of special nature as the main activity,and who employ less than 50 employees in one year, and whose total annual financial balance sheet is less than 25 million Turkish Lira must be registered to the Registry 30.09.2020.
  • Data Controllers who are qualified as public institutions and organizations must be registered to the Registry until 30.09.2020.

The registration shall be done through VERBIS, which can be accessed from the www.kvkk.gov.tr web site.