With the implementation of the Law on the Protection of Personal
Data No. 6698 (LPPD)
and its secondary regulations, the Data Protection
Authority (DPA), tasked with monitoring
violations of LPPD obligations, have started to
impose administrative fines to persons
and/or companies violating their obligations set forth at the LPPD.
Although Article 18 of the LPPD does state the monetary fines
applicable to such violations, it did so by determining a lower and
upper limit for administrative fines. This not an uncommon practice
as most administrative fines stated in other legislation in Turkey
are determined this way, giving discretionary powers to the
relevant authority imposing the fines (although there are also
fixed administrative fines determined in other legislation).
However, difference between the lower and upper limits set forth by
the LPPD is high enough (the fines can range from TRY5.000 up to
TRY1.000.000 depending on the type of violation) to cause
