Differences Between The KVKK And The GDPR

I. DEFINITION OF PERSONAL DATA

Pursuant to Article 3 of the Law No. 6698 on the Protection of Personal Data (“KVKK”), personal data is defined as any information relating to an identified or identifiable natural person. Although the concept is expressed in these terms under Turkish law, different legal systems adopt different approaches. Under the General Data Protection Regulation of the European Union (“GDPR”), which constitutes the general framework in this field, personal data is defined as “any information relating to an identified or identifiable natural person”. Based on this definition, it may be stated that personal data is regarded under EU legislation as a value pertaining specifically to “natural persons”. By contrast, Certain approaches in Anglo-American legal scholarship and practice have placed greater emphasis on the economic and proprietary aspects of personal datahaving economic value. Accordingly, this approach addresses personal data primarily within the framework