In the event that some or all of the personal data is transferred to the founder / partner foreign company located abroad and the foreign company uses this data for its own purposes, there is an obligation to register with the Data Controller’s Registry Information System (“VERBIS”). These transfers, in general, consist of recordings of all or part of the data of the employees, suppliers and customers of the legal entity in Türkiye to a registration system which is provided and managed by foreign partner. However, keeping only personal data in a registration system by the foreign partner does not constitute VERBIS registration obligation and the foreign partner should use this data for their own purposes.

According to the numbered 2019/265 decision of the Personal Data Protection Board (KVKK) dated 03/09/2019, obligation to register at Data Controllers' Registry Information System ("VERBIS") has been extended until 31.12.2019.

The Circular on Information Security in Public Institutions and Organizations has been published in the Official Gazette

Circular no 2019/12 on Information and Communication Security Measures specifying a serious of measures to ensure the security of data that may have an impact on public order and national safety was published in the Official Gazette No. 30823, dated July 6, 2019. The Circular that consists of 21 articles has aroused interest with many articles contained therein. We may classify the prominent issues in the said publication as below:

In the 28 April 2019 dated and 30758 numbered Official Gazette, certain amendment texts directly related with the law on protection of personal data legislation, have been published. These amendments have been done in legislations of purge/destruction/anonymization of personal data, VERBIS and the obligation to inform, are respectively as follows:

• Regulation on Purging, Destruction and Anonymization of Personal Data
• Regulation on the Data Controllers’ Registry System
• Communiqué on Procedures and Principles to Be Followed in Fulfilling Obligation to Inform