General Data Protection Regulation (GDPR) & Turkish KVKK Compliance

International companies operating in Turkey face a dual data protection compliance obligation that is more complex than either framework alone. Turkey's Law No. 6698 on the Protection of Personal Data (KVKK) applies to the processing of personal data within Turkey and, extraterritorially, to foreign controllers processing Turkish individuals' data. The EU's General Data Protection Regulation (GDPR) continues to apply to many of those same companies through their European operations or their EU customer relationships. The two frameworks share a common conceptual foundation but differ in ways that matter operationally, particularly around cross-border data transfers, VERBİS registration, supervisory authority procedures, and enforcement exposure.

Key Dual-Compliance Requirements for Foreign Entities

When foreign businesses establish commercial presence or manage digital services in Turkey, data privacy compliance requires specific legal mapping:

• • VERBİS Registration: Foreign and domestic data controllers meeting statutory criteria must register with the Data Controllers Registry (VERBİS) prior to data processing.
• • Cross-Border Data Transfers: Aligning Turkish KVKK cross-border transfer mechanisms (Standard Contractual Clauses, binding commitments, or explicit consent) with EU GDPR adequacy requirements.
• • Data Processing Agreements (DPAs): Drafting compliant vendor contracts, joint controller agreements, and localized privacy policies.
• • Data Subject Rights & Breach Notifications: Managing mandatory data breach notifications to the Turkish Personal Data Protection Board (KVKK) within statutory time limits (72 hours).

For international entrepreneurs establishing corporate operations, coordinating compliance alongside company formation services in Turkey ensures complete legal readiness.

At Legal Turkey, our data privacy team advises multinational corporations, tech firms, and foreign investors on harmonizing their global GDPR policies with local Turkish KVKK mandates. Contact Legal Turkey today to schedule a consultation with our privacy lawyers in Istanbul.