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Registration Deadline to Data Controllers Registry Has Been Extended For 6 Months

Registration obligation (“Obligation”) to Data Controllers Registry (“Registry”, in Turkish, “VERBIS”) has been issued as a legal obligation for both natural and legal person data controllers as per Article 16 of the Turkish Personal Data Protection Code numbered 6698.

As noted in our previous Newsletter dated September 2019, the registration deadline had already been extended to 31 December 2019 by Personal Data Protection Authority (“Authority”).

Lastly, the deadline of this obligation has been extended by the Authority once again with the decision numbered 2019/387 dated 27 December 2019 published on its website.

Accordingly, the new deadlines are as follows:

I. Ex-Deadlines for the Obligation

December, 2019

Data Controllers Starting Date Duration Deadline
1 Data controllers whose number of employees exceeds 50 or whose annual balance sheet total (total assets on the balance sheet) exceeds TRY 25 million 01.10.2018 15 months 31.12.2019
2 Data Controllers residing abroad 01.10.2018 15 months 31.12.2019
3 Data controllers whose number of employees lower than 50 or whose annual balance sheet total (total assets on the balance sheet) is lower than TRY 25 million 01.01.2019 15 months 31.03.2020

II. New Deadlines for the Obligation

Data Controllers Starting Date Duration Deadline
Data controllers whose number of employees exceeds 50 or whose annual balance sheet total (total assets on the balance sheet) exceeds TRY 25 million 01.10.2018 15 months 30.06.2020
Data Controllers residing abroad 01.10.2018 15 months 30.06.2020
Data controllers whose number of employees lower than 50 or whose annual balance sheet total (total assets on the balance sheet) is lower than TRY 25 million 01.01.2019 15 months 30.09.2020
State Institutions and Organizations 01.04.2019 15 months 31.12.2020

As it can be clearly seen from these charts, data controllers who have not yet completed the necessary steps of registration to the Registry shall have additional 6 months to ensure the compliance and fullfill this obligation.

Our Law Firm remains at your disposal for any further clarifications you may need.

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