Recent Decisions Of The Turkish Data Protection Board (June 2021)

The Turkish Data Protection Board ("Board") has recently published quite a number of decisions. Among those, some are important for certain matters of public interest and may constitute precedents for future cases. We have summarized such decisions below, along with explanations as to their significance.

Decision Regarding Factors to Be Considered In Determining the Parties' Roles as Data Processor and Data Controller, and Allocation of the Duty to Inform¹

This decision is significant because it sets out illustrative criteria for allocating and identifying the roles of data processor and data controller in any given data processing activity. In the decision, the Board clarified that while the duty to inform rests with the data controller as a general rule, the data controller may authorize third parties to fulfill this duty, and as such, the data processor may be authorized to fulfill the data controller's duty to inform. The Board stated that the parties can