According to the Article 16 of KVKK, natural and legal persons who process personal data must register with VERBIS (Data Controllers' Registry Information System) before starting data processing.

In this regard, the deadlines determined by Turkish Data Protection Authority for registration to VERBIS as below.

As it is known, the principles of transfer of personal data abroad are regulated in Article 9 of KVKK. According to this regulation, in transfers to countries that are not counted among adequate countries, with a commitment to be signed between the person to whom the transfer will be made and the person who will make the transfer, permission must be obtained from the Board. However, adequate countries have not yet been announced by the Authority and it is likely that it will take time to identify safe countries, as we see from the "Criteria to be Based on Determining Countries with Sufficient Protection" published by the Authority. Since the adequate countries have not yet been announced, although people go for permission from the Board, there are also some difficulties in this process. Considering these difficulties, the Authority announced the Binding Corporate Rules institution and announced the method to facilitate data transfer for multinational group of companies. In this method announced, the process of obtaining permission from the Board will be carried out, as well. However, it should be noted that although a different alternative has been presented by the Authority, the question marks in transferring abroad have still not been eliminated, since the adequate countries have not been announced yet. Besides, as we will explain below, the announcement that the application of the Binding Corporate Rules will be finalized by the Authority in 1 year and this period will likely to be extended for 6-month periods shows that this process will not be short, as well.

The "Pandemic Isolation Tracking Project", which aims to observe the movements of quarantined people and regions, has been announced by the Presidency Of The Republic Of Türkiye; in the announcement, it is stated that the aim of the project is to make analysis to prevent further spread of the epidemic.

In the project, which will be carried out in cooperation with the Ministry of Health, Information Technologies and Communications Authority and all GSM operators, it has been realized that the location information of the individuals will be monitored by GSM operators, which may violate personal data security and privacy.

By publishing an announcement regarding the subject on 09.04.2020, the Personal Data Protection Authority has declared that the processing of the location data by the authorized institutions and organizations in order to prevent further spread of the pandemic will be considered under the exception of the Article 28 of KVKK, as the epidemic disease threatens public safety and public order; in other words, that the Law shall not be applied for this activity.

Due to the Covid-19 Coronavirus epidemic, which is on the agenda of the whole world, many companies switched to remote working. However, some companies could not start working remotely, from homes due to lack of technical infrastructure, while some companies switched to remote working in means of working from home without being aware of the systems that they had to set up in their technical systems and without taking the necessary precautions.

Among the guideline of frequently asked questions published by Turkish Personal Data Protection Authority (KVKK) and ICO on the subject, the question "What kind of security measures should be taken to work from home?" has been answered stating that data protection is not a barrier to working from home and that usual security measures should be applied during working remotely, as well.

In the Guidelines for Safe ‘Remote Work’ published by the National Cyber Incidents Response Center within the scope of corona virus outbreak measures, the importance of the measures are described as follows: Defining a time-out for maximum connection time on systems, temporary establishment of the rules defined during remote work, "source IP" restrictions for remote connections where possible, multi-factor authentication and time-based authorization measures for access, ensure that remote access is not permitted for access to any critical systems that should not be defined according to the risk assessment.

So, what aspects should companies take into consideration when working remotely?