VERBIS Registration of Branches and Liaison Offices of
Data Controllers That Are Not Located in
Turkey
On October 7, 2019, the Turkish Personal Data Protection
Authority ("Authority") published a new
decision summary on its website. The Authority's decision w.
no. 2019/225 covers the VERBIS registration (Data Controller
Registry) requirement of branches and liaison offices of
non-resident legal persons in Turkey. With this decision; it is
decided that the branches of non-resident legal persons in Turkey
shall be registered under certain conditions however the liaison
offices do not have to register.
The Authority made the following assessments in its
decision;
According to the Law on Protection of Personal Data
("the Law") w. no. 6698; "The
Data Controller is the natural or legal person who
determines the purpose and means of processing personal data and is
responsible for establishing and managing the data registry
system." Under the subparagraph 4 of Article
