KVKK compliance and requirements in Türkiye, so your data handling holds up when someone asks.

What it is

What is KVKK, Türkiye's Personal Data Protection Law, and what is it used for?

Law No. 6698 on the Protection of Personal Data (KVKK) is Türkiye's data protection law. It sets processing principles and conditions, stricter conditions for special categories such as health and biometric data, duties to inform individuals and answer their requests, security measures, breach notification, registration with the Data Controllers' Registry (VERBİS) and a transfer-abroad regime. Law No. 7499 of 2 March 2024 rebuilt the transfer rules around adequacy decisions, appropriate safeguards and incidental exceptions.

The Personal Data Protection Authority, acting through its Board, enforces the Law and runs VERBİS, a breach notification form, a complaint module and the standard contract for transfers. Any business holding staff, customer, patient or user data in Türkiye is in scope. The practical test: for any personal data you hold, could you show its basis, who was told, how it is protected, whether it is registered and where it goes?

Current law. Law No. 6698 was published in the Official Gazette on 7 April 2016 and has been amended since, including by Law No. 7499 of 2 March 2024, which rebuilt the transfer-abroad rules and changed the conditions for special categories of data. Contracts and transfer arrangements drafted before 2024 are the first things worth checking. Confirm current wording and the Board's decisions with your legal advisers.

Who it is for

Who needs to comply with KVKK?

The Law applies to natural and legal persons that process personal data, whatever their size, including employers holding staff records. Organisations usually come to Sterling for a structured programme from one of four directions:

• You must register in VERBİS. Persons who process personal data register with the Data Controllers' Registry before processing, unless the Board grants a derogation, describing purposes, recipients, transfers abroad and security measures.
• Personal data goes abroad. Groups, cloud users and exporters need each transfer mapped to an adequacy decision, an appropriate safeguard such as a standard contract or binding corporate rules, or a narrow incidental exception.
• You process data for others. A controller is jointly responsible with its processors for security measures, so software, outsourcing and contact-centre firms are asked for contracts and audits.
• You handle special categories of data. Employers, clinics, retailers and platforms holding health, biometric and similar data face stricter conditions for processing it.

The aim is handling of personal information that you control and can evidence. Compliance depends on how the rules are applied every day, not on a policy document alone.

Requirements

What are the main KVKK requirements?

Strip away the vocabulary and Türkiye's KVKK asks a business to comply in six areas of personal data handling. The list below puts each one in business terms; the Law and the regulator's guidance give the full wording and exceptions.

• Processing has a lawful basis: personal data is processed fairly, for specific legitimate purposes and only as far as needed, on a lawful condition; special categories such as health data face stricter conditions.
• People are told what happens: when data is collected, individuals learn who the controller is, why it processes the data, who may receive it, how it was collected and what rights they hold.
• Individuals' requests are answered: requests to learn about processing, correct or erase data, object to purely automated results or claim compensation are answered promptly, in writing or electronically.
• Data is secured and breaches reported: technical and organisational measures prevent unlawful access, processors are covered, audits are carried out, and a breach is notified to the individual and the Board within the shortest time.
• Controllers register before processing: unless the Board grants a derogation, organisations that process personal data register with the Data Controllers' Registry first, describing purposes, recipients, transfers abroad and security measures.
• Transfers abroad follow set routes: data leaves Türkiye only with an adequacy decision or an appropriate safeguard, such as a standard contract or binding corporate rules, or under narrow incidental exceptions.

Compliance route

How do you achieve KVKK compliance?

There is no certificate at the end of this route. Compliance is something your organisation demonstrates, to the Personal Data Protection Authority if a complaint or incident arises, and to customers who ask. Sterling helps you build and run the programme; interpretation of the law in contested cases remains with your legal advisers and, ultimately, the regulator and the courts.

1. 01
   Map the personal information you handle.Staff, customers, patients, users and suppliers: what is collected, on which condition, where it is stored, who processes it, whether it is registered in VERBİS and whether it leaves Türkiye.
2. 02
   Gap analysis: compare current practice with the Law.Each area of the Law reviewed against what actually happens, with actions, owners and dates agreed.
3. 03
   Put the controls and routines in place.Update notices, set rules for special categories, put security measures and processor contracts in place, complete or update the VERBİS registration, map each transfer abroad to its route and agree a breach procedure.
4. 04
   Test the programme and review the results.Internal review of samples, a simulated incident or data-subject request, and a management review that closes findings with evidence.
5. 05
   Operate, demonstrate and keep it current.Answer requests promptly, record incidents, keep VERBİS current, review transfers, refresh training and follow the Board's decisions and guides as they are issued.

Check the route before you sign. The Law creates no certificate of conformity, so treat any offer of a "KVKK certificate" with suspicion. If a customer wants independent assurance, ISO/IEC 27701 or ISO/IEC 27001 is certifiable by an accredited certification body; confirm the body's accreditation scope directly with the accreditation body concerned.

Cost

How much does KVKK compliance cost?

The cost of a KVKK programme is driven by how much personal information you hold, how many systems and suppliers touch it, and how much already works. Your proposal shows each component, with what is included and what remains for your legal advisers.

Timeline

How long does KVKK compliance take?

Timing depends on how scattered your personal information is, how quickly system owners respond and how much has to change. Your proposal sets out the phases for your scope, long enough to map the information, fix the gaps and show that requests and incidents are handled the way the procedures say.

If a customer or contract has set a date, tell us at the outset and we will say plainly what can be in place by then and what should follow.

Your engagement

What your KVKK engagement includes

Your scope covers the full programme, from the information map to evidence that runs. Sterling does not certify, attest or validate compliance with the Law, and the Law creates no certificate of compliance; the Personal Data Protection Authority supervises it, and we work alongside your legal advisers.

• Information map, gap analysis and plan

  Sources, systems, suppliers and overseas flows, with actions and owners agreed.

• Policies, notices and procedures

  Notices, request, security and breach procedures, processor contract terms and transfer documents, drafted from Sterling's own templates with your teams.

• Effivity ISO & GRC software

  Registers, requests and incidents managed in Effivity, included with the engagement at no additional cost.

• Training for everyone

  Internal auditor training for your review team, as applicable to your standard, and preferential Sterling Academy access, including complimentary awareness training for your people as part of the engagement.

• Internal review and management review

  Sample testing, an incident exercise and findings closed with evidence.

• VERBİS and transfer support

  Help preparing registry entries and mapping each transfer abroad to an adequacy decision, safeguard or exception.

Sterling OS™ sets how we deliver. Design™ is guided support, where your team builds the programme with our consultants' direction; Drive™ is managed support, where our consultants do most of the work with your input. You choose one of the two, not both in sequence. Once the programme is operating, Sustain™ keeps reviews, training and updates on schedule, and Automate™ is Effivity, where the records live.

The Personal Data Protection Authority in Ankara, acting through its Board, enforces the Law.

Often combined with

Standards organisations pair with KVKK (Türkiye)

• ADGM Data Protection Regulations 2021ADGM data protection compliance for entities under the 2021 Regulations: lawful bases, DPO, impact assessments, 72-hour breach notice and transfers, all-inclusive proposal.
• APEC CBPRAPEC CBPR certification and requirements explained: Global CBPR and PRP, Accountability Agent review, annual renewal and how Sterling prepares your team.
• APPI (Japan)APPI compliance for Japan's Act on the Protection of Personal Information: the requirements, PPC breach reporting, cross-border rules and an all-inclusive programme.
• Bahrain PDPLBahrain PDPL compliance and requirements explained: consent, notification to the Authority, transfers abroad, 72-hour breach reporting, rights, cost and timing.
• CCPA / CPRACCPA compliance and requirements under the CPRA: notices, consumer rights, opt-outs, risk assessments, cybersecurity audits and ADMT, in an all-inclusive programme.
• Cyber and Data Protection Act (Zimbabwe)Zimbabwe's Cyber and Data Protection Act [Chapter 12:07]: POTRAZ licensing, lawful processing, security and transfers, built into a programme.