The Data Protection Board ("Board") published its
decision on 7 October 2019 regarding possible registration
obligation of branches and liaison offices of foreign companies in
Turkey with the Data Controllers' Registry (The newly published
decision was actually taken by the Board on 23 July 2019 with a
decision number 2019/225 upon an opinion request directed to it
earlier on.). You can read the Decision, only available in Turkish,
here.
The Board's decision includes a detailed explanation and
assessment of the Turkish legislation on branches formed by foreign
companies in Turkey; as well as the Turkish Data Protection Law and
the GDPR. As a result of its evaluation, the Board notes that both
the foreign entity and its branch in Turkey would be data
controllers for purposes of their data processing activities. The
Board acknowledges that these branches lack "legal
persona", thus they do not qualify as "legal
entity"; but considers that the branches established in
