Pursuant to Article 16 of the Law No. 6698 on the Protection of Personal Data ("Law"), real or legal persons processing personal data must register with the Data Controllers' Registry (tr. VERBIS) before processing personal data.
Pursuant to the Personal Data Protection Board's decision numbered 2021/238, the following data controllers must register with VERBIS by December 31, 2021:
- Real or legal person data controllers that have more than 50 employees in a year or an annual balance sheet above TRY 25 million (approx. USD 2.6 million)
- Real or legal person data controllers that have less than 50 employees in a year and an annual balance sheet below TRY 25 million (approx. USD 2.6 million), principle business activity of which is processing special categories of personal data
- State institutions and organizations
- Data controllers residing outside of Turkey
The relevant data controllers may review the Guidelines for Data Controllers' Registry Information System for their registration processes. The guidelines are available here (in Turkish).
Conclusion
According to Article 18 of the Law, data controllers that fail to fulfill their VERBIS registration and notification obligations may be subject to administrative fines under the Law. In that regard, all relevant data controllers must complete their VERBIS registrations by December 31, 2021.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.