Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 07 NOVEMBER 2018

Understanding The Registration Obligation Under Turkish Data Protection Law

ELIG Gürkaynak Attorneys-at-Law
ELIG Gürkaynak Attorneys-at-Law
Contributor
ELIG Gürkaynak Attorneys-at-Law

ELIG Gürkaynak Attorneys-at-Law

ELIG Gürkaynak Attorneys-at-Law is an eminent, independent Turkish law firm based in Istanbul. The...

View firm profile
Explore more from ELIG Gürkaynak Attorneys-at-Law

Data controllers processing personal data in the Turkish jurisdiction (including processing activities that are conducted abroad, but have an effect in Turkey) are required to enroll to the Data Controllers' Registry.

TurkeyPrivacy
Gönenç Gürkaynak
Gönenç Gürkaynak
İlay Yılmaz
İlay Yılmaz
Burak Yeşilaltay
Burak Yeşilaltay
Author LinkedIn connections

I. Scope of the registration obligation under Turkish legislation

Data controllers processing personal data in the Turkish jurisdiction (including processing activities that are conducted abroad, but have an effect in Turkey) are required to enroll to the Data Controllers' Registry ("Registry"). This requirement is regulated under Article 16/2 of the Data Protection Law ("DP Law"), which expressly states that "real persons or legal entities processing personal data are obliged to enroll to the Data Controllers' Registry." Although the letter of the law seems applicable to all data controllers, the Data Protection Board ("Board") has introduced certain exemptions to this obligation, which will be explained in detail below.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

Turkiye Introduces New Age Verification And Child Protection Requirements For Social Network Providers

On 10 October 2026, the Regulation on the Provision of Differentiated Services for Children and Age Verification by Social Network Providers (the "Regulation") was published in the Official Gazette. Issued by the Cyber Security Presidency, the Regulation introduces mandatory age verification, restrictions on children's access to social networks and additional safeguards for users aged 15 to 17.
TurkeyPrivacy
Balcıoğlu Selçuk Eymirlioğlu Ardıyok Keki Attorney Partnership
Balcıoğlu Selçuk Eymirlioğlu Ardıyok Keki Attorney Partnership
Article

New Regulations For Protecting Children On Social Media In Turkey Minimum Age, Age Verification & Parental Controls

While the widespread use of social media by children offers significant opportunities for communication and access to information, it also presents various risks, including exposure to harmful content, cyberbullying, online exploitation, and threats to the protection of personal data. These risks have increased the importance of legal regulations aimed at protecting children in the digital environment.
TurkeyPrivacy
ADMD/Mavioglu & Alkan Law Office
ADMD/Mavioglu & Alkan Law Office
Article

New Age Verification And Child-Specific Service Obligations Introduced For Social Network Providers

Turkey's new regulation mandates strict age verification and child-specific protections for social media platforms, prohibiting services to users under 15 and requiring segregated, privacy-enhanced accounts for those aged 15-17. Social network providers must implement parental controls, restrict targeted advertising and profiling, and establish transparent appeal mechanisms, with enforcement beginning November 2026.
TurkeyPrivacy
Moroglu Arseven
Moroglu Arseven
Article

Data Protection Law In Turkey (KVKK): Compliance Obligations For Businesses

This article examines Turkey's personal data protection framework under Law No. 6698 from the perspective of companies operating in, selling into or otherwise handling data connected with the Turkish market. It addresses the distinction between data controllers and processors, lawful processing, the information duty, the 2024 reform of special-category data and cross-border transfers, the 2025 VERBIS exemption update, data subject requests, breach response and enforcement.
TurkeyPrivacy
ONGUR & PARTNERS
ONGUR & PARTNERS
Article

KVKK Yurt Dışı Veri Aktarım Rehberi

6698 sayılı Kişisel Verilerin Korunması Kanunu’nun (“KVKK”) 9 uncu maddesi kapsamında kişisel verilerin yurtdışına aktarımlarının uygulanması ile Kişisel Verileri Koruma Kurulu’nun (“Kurul”) beklediği uygun güvenceler hakkında kamuoyunun aydınlatılması amacıyla Kişisel Verileri Koruma Kurumu (“Kurum”) tarafından 2 Ocak 2025 tarihinde Kişisel Verilerin Yurt Dışına Aktarılması Rehberi (“Rehber”) yayımlanmıştır.
TurkeyPrivacy
Barlas & Karabucak Law Firm
Barlas & Karabucak Law Firm
Article

A New Era For Children And Gaming In Turkey: Understanding Law No. 5651’s 2026 Amendments For Providers And Platforms

On April 2 2026, the Turkish Grand National Assembly’s (“TBMM”) Health, Family, Employment, and Social Affairs Commission approved a transformative set of amendments to Law No. 5651 on the Regulation of Publications on the Internet and Combatting Crimes Committed by Means of Such Publications (“Law No. 5651”), which were published in the Official Gazette of May 1, 2026.
TurkeyMedia, Telecoms, IT, Entertainment
ELIG Gürkaynak Attorneys-at-Law
ELIG Gürkaynak Attorneys-at-Law
Article

Turkish Competition Board Finds No Infringement In A101 And CarrefourSA Parallel Pricing Investigation

The investigation originated from a series of consumer complaints submitted from late 2023 onwards, which pointed to identical or closely aligned prices for products such as eggs, yoghurt, rice, butter and wafers across several national grocery retailers. The complaints also alleged that price increases were frequently implemented on the same or nearby dates.
TurkeyAntitrust/Competition Law
ELIG Gürkaynak Attorneys-at-Law
ELIG Gürkaynak Attorneys-at-Law
Article

Navigating The AXA/Denizbank Decision: The Boundaries Of Exclusivity, Non-Compete, And No-Poaching Obligations In Bancassurance Agreements

The Turkish Competition Board’s (“Board”) recent decision involving the negative clearance and exemption application of AXA Sigorta AŞ (“AXA”) concerning the Non-Life Insurance Agency Agreement (“Agreement”) concluded with Denizbank AŞ (“Denizbank”) and Deniz Finansal Kiralama AŞ (“DFK”) serves as an important decision in Turkiye’s non-life insurance and bancassurance markets (“Decision”).
TurkeyCorporate/Commercial Law
ELIG Gürkaynak Attorneys-at-Law
ELIG Gürkaynak Attorneys-at-Law
Article

Digital Transformation In Packaging: Compliance Deadlines For E-Leaflets, QR Codes, And Anti-Tampering

The Turkish Medicines and Medical Devices Agency ("TİTCK") has updated its Guideline on Packaging Information and Patient Information Leaflets for Medicinal Products for Human Use ("Guideline"), with its latest revision dated August 11, 2026. Issued under the Regulation on Packaging Information, Patient Information Leaflets and Tracking of Medicinal Products for Human Use ("Regulation"), the Guideline sets out requirements concerning pharmaceutical packaging, patient information, and product safety.
TurkeyPrivacy
ELIG Gürkaynak Attorneys-at-Law
ELIG Gürkaynak Attorneys-at-Law
Article

The High Court Of Appeals Allows Extraordinary Termination Based On “Important Reasons” For Residential And Roofed Workplace Leases

Under the Turkish Code of Obligations No. 6098 (“TCO”), residential and roofed workplace lease agreements are subject to a special termination regime. In principle, early (extraordinary) termination is permitted only under specific and limited statutory grounds. The High Court of Appeals, in its decision numbered 2025/3126 E., 2025/4810 K. that is published in the Official Gazette dated March 12, 2026 and numbered 33194 (“Decision”), addressed whether the extraordinary termination based on “important reasons”, as regulated under Article 331 of the TCO, can be applied to residential and roofed workplace leases.
TurkeyReal Estate and Construction
ELIG Gürkaynak Attorneys-at-Law
ELIG Gürkaynak Attorneys-at-Law