As you may remember from our Newsletter concerning ‘VERBIS’ (Data Controllers Registry), pursuant to the decision of the Personal Data Protection Authority  (“Authority”) published on 25 June 2020 in the Official Gazette, the new deadlines for the registration with the Data Controllers Registry (VERBIS) had been extended. We reminded you with our previous Newsletter dated 29 September 2020 of the different extension dates that were provided to data controllers with respect to their registrations.

Pursuant to the public announcement published by the Authority today on 1 October 2020, the Presidency of the Authority has determined that there are 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, who haven’t sent their applications for registration through their Electronic Registered Mail (in Turkish “KEP”) or who haven’t completed their notifications after having applied for registration, having missed the deadline of 30 September 2020.

According to the said announcement, with the decision of the Authority dated 1^st October 2020 and numbered 2020/760 yet to be published,according to article 8 of the Regulation on the Registry of the Data Controllers and within the scope  of  the powers given to the Authority with provisional article 1 of the Turkish Code on the Protection of Personal Data, it has been decided to notify in writing the data controllers who have not fulfilled their obligation to register to “VERBIS”,.

It is important to clarify that the registrations to VERBIS are continuing. In other words, the companies, which could not complete their VERBIS registration as of 30^th September 2020 can continue their process of registration without waiting any notification from the Authority.

On the other hand, we suggest you to regularly check Electronic Registered Mail Address of your company and if you receive any notification from the Authority in this respect, to apply to the Authority without any delay mentioning the reason of your impossibility to be registered on time. You may primarily state the extenuating circumstances of Covid-19 to be your excuse (detailing the situation for your company), in order to avoid any potential sanctions. In such case, an additional 30- day of extension will most probably be granted by the Authority.

We will continue to keep you informed, if any further clarifications are announced in this respect by the Authority.

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