ANNOUNCEMENT OF PERSONAL DATA PROTECTION BOARD ON THE REGISTRATION WITH DATA CONTROLLERS’ REGISTRY (“VERBIS”)
With reference to our Newsletters dated 16 March 2021 and 13 October 2021 whereby we informed you on the obligation to register with Data Controllers Registry (in Turkish, “Veri Sorumluları Sicil Bilgi Sistemi”, in short “VERBIS”) and on the postponed registration deadlines, now we would like to draw your attention on a very recent public announcement of Personal Data Protection Board (in short the “Board”) which was published on its website on 21 April 2022.
In the said announcement, the Board highlights its decision dated 11 March 2021 and numbered 2021/238 where the following data controllers were required to complete their registration with VERBIS until 31 December 2021 and the Board announces that the Board has started to impose the administrative fines to the data controllers which fail to comply with VERBIS registration obligation as per Article 18 of the Law numbered 6698 on the Protection of Personal Data (the “Law”). As per Article 18/1 (ç) of the Law, for those who act contrary to the obligation for the registry with VERBIS and for notification provided for in the Article 16 shall be imposed to pay an administrative fine of between TRY 53.572.- (approximately EUR 3,350) and TRY 2.678.863 (approximately EUR 167,500) for the year 2022 may be imposed against the relevant data controller.
| Data Controllers | Deadline |
| Data controllers whose annual number of employees exceeds 50 or whose annual balance sheet total (total assets on the balance sheet) exceeds TRY 25 million | 31.12.2021 |
| All real persons or legal entities processing personal data of any Turkish resident as data controllers located outside Turkey irrespective of their number of employees and balance sheet value, | 31.12.2021 |
| Data controllers whose (i) number of annual number of employees is lower than 50 and whose annual balance sheet total (total assets on the balance sheet) is lower than TRY 25 million and (ii) whose main field of activities is processing sensitive personal data (in Turkish, “özel nitelikli kişisel veri”) | 31.12.2021 |
| Public Institutions and Organizations, Professional Organizations with Public Institution Status (in Turkish “Kamu Niteliğindeki Meslek Kuruluşu”) | 31.12.2021 |
Our Law Firm remains at your disposal for any further clarifications you may need.