Introduction
Shortly after its establishment with the Turkish Data Protection
Law No. 6698 ("Law"), the Turkish Data
Protection Authority ("DPA") has started
to observe the data protection ecosystem of Turkey. In this regard,
the DPA has been focusing on the areas, where data protection
concerns are perceived more concentratedly. One of the instruments
that the DPA has been putting to use is adopting resolutions, where
the violation is prevalent. It is worth to note that
"resolutions" are different than
"decisions" in nature within the meaning of the
Law.
As paragraph 6 of Article 15 proposes, "As a result of
the inspection conducted either ex
officio or upon complaint, in case it is
determined that the violation is prevalent, the Board shall adopt
a resolution and publish
it." Differently from the DPA's
decisions, resolutions are adopted in
cases where the violation not only exists but also prevalent. Also,
the Law supposes that the resolutions must be
