The Turkish Competition Board Declares Zero Tolerance Policy Against Deleting Data During On-site Inspections

The Turkish Competition Board ("Board") has recently published four decisions¹ where it decided to impose administrative monetary fines of five in thousands of the annual turnover of the relevant undertaking for hindering/obstructing the on-site inspection by way of deleting data (i.e., e-mails and WhatsApp messages) as per Article 16 of the Law No 4054 on Protection of Competition ("Law No. 4054")². In these decisions, the Board ignored the steps taken to compensate the result, such as voluntarily handing over the data (which were considered to be deleted). This article first provides a general context for the subject and then brief summaries of the relevant four decisions, which may be considered as a declaration of the Board's zero tolerance policy towards deleting data.