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Turkish data privacy authority postpones VERBIS registrations

Turkiye
27/12/2019
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On 27 December 2019, the Turkish Data Protection Board (“DPB”) announced the second postponement of the deadline for registration with the Data Controllers Registry Information System (VERBIS).

The deadlines for registering on VERBIS have been extended six months from the expiry date of each type of data controller. Information on previous deadlines can be found here.

The current deadline for registration with VERBIS for each group of data controller is as follows:

Type of data controller Start date End date
1 Data controllers who have more than fifty (50) employees or an annual balance sheet total of more than TRY 25,000,000.00 (twenty-five million Turkish lira). 01.10.2018 30.06.2020
2 Data controllers residing in foreign jurisdictions. 01.10.2018 30.06.2020
3 Data controllers with less than fifty (50) employees and an annual balance sheet total of less than TRY 25,000,000.00 (twenty-five million Turkish lira) whose main field of operation is the processing of sensitive data. 01.01.2019 30.09.2020
4 Data controllers that are governmental institutions and organizations. 01.04.2019 31.12.2020

While the DPB has granted an extension for data controllers for registration with VERBIS, it has also stated that there have been many inconsistencies with the VERBIS registrations already received. Specifically, the DPB has stated that the information submitted to VERBIS is inconsistent with the personal data inventory of the data controller in question.

As such, for data controllers already registered with VERBIS, it would be advisable to review their existing data privacy documents (specifically the data inventory) and policies prepared to this effect and ensure that the information submitted to VERBIS is in line with such documentation.

As for the data controllers that have not yet registered with VERBIS, it would be advisable to prepare the relevant documentation strictly in compliance with the applicable legislation and in a manner that reflects the data privacy practices of such data controller and ensures that the information submitted to VERBIS is consistent with the said documentation and policies.

Please do not hesitate to contact your regular CMS source or local CMS experts Dr. Döne Yalçın or Sinan Abra for further details on VERBIS registration and any other data privacy related questions.

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