Where Should KVKK Compliance Begin?

For many businesses, KVKK compliance is seen as little more than adding a privacy notice to the website. In fact, the Law covers the entire life cycle of personal data, from collection to destruction. To build compliance on solid ground, a company first needs a clear picture of which data it processes, for what purposes and by which departments.

1. Data inventory: An inventory showing, for each department, the categories of personal data processed, the purposes and legal bases of processing, retention periods and the groups of recipients to whom data is transferred is the foundation of any compliance programme.

2. Duty to inform: When data is collected, data subjects must be informed of the identity of the data controller, the purposes of processing, the parties to whom data may be transferred, the method of collection and legal basis, and their rights under Article 11 of the Law.

3. Legal basis and explicit consent: Explicit consent is only one of the processing conditions set out in the Law. Where another condition applies — such as performance of a contract, a legal obligation or legitimate interest — relying on consent may be both unnecessary and misleading.

4. Technical and organisational measures: Restricting access rights, encryption, logging, confidentiality undertakings with employees and regular training are essential parts of the data security obligation.

Once these steps are complete, the company should register with VERBİS where required and review the process at regular intervals. Since every business is structured differently, its compliance programme must be designed specifically for it.