04September2018

Registration Deadlines to the Registry of Data Controllers Has Been Announced

Within the scope of the Personal Data Protection Law numbered 6698 which has been announced in the 29677 Numbered Official Gazette dated April 7, 2016, it is highly crucial for the natural persons and legal entities to meet all the legal compliancy requirements in dealing with the personal data that they obtain, use, store, process to avoid the administrative penalty fines and possible incompliancy sanctions.

On July 19, 2018 a provisional clause to the Law has been declared with the Decision Number: 2018/88. The aim of the Article 1 of the Provisional Clause is to declare the deadlines the business organizations need to consider for the necessary registrations to be made at the Data Controllers’ Registry. The organizations that are responsible to finalize the registration by the expected dates are outlined in the table (Table1) below.

Data Controllers Responsible for the Registration (Natural Persons or Legal Entities – Workplace Specifications)	Registration Start Date, Announced by the Board	Registration Deadline, Announced by the Board
Natural and legal persons with more than 50 registered employees for one calendar year and/or annual financial statement exceeds 25.000.000 TRY	01 October 2018	30 September 2019
Natural and legal persons with less than 50 registered employees for one calendar year and/or annual financial statement is below 25.000.000 TRY, with the core business being data processing activities	01 January 2019	31 March 2020
Public Organizations/Institutions entitled as Data Controllers	01 April 2019	30 June 2020
Natural and legal persons resident abroad, entitled as Data Controllers	01 October 2018	30 September 2019

(Table 1)

Overall, certain exemptions to the registration of the Data Controllers’ Registry might be imposed and the entities might be waived from the liability with the analysis of the data that is processed, transfer of data to the third parties, etc. which is to be handled by the Board.

For further information in regards the subject, please refer to the Board’s own informative publication, published in Turkish.

You may access the up-to-date table including the deadlines for VERBIS registration from our article in the link.

Author CottGroup Hukuk ve Mevzuat Ekibi, Category Personal Data Protection Law, Labor Law

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