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.