Data controllers must manage the topics of the duty to inform, explicit consent, data processing conditions, data security, and cross-border transfers together with their operational processes.
Key steps in KVKK and GDPR compliance
This publication outlines, in general terms, the topics that companies should take into account in their decision-making process. Application may vary depending on the sector and the specific structure of the transaction.
Practical takeaways for companies
- The relevant legislation and practice should be assessed on a current basis.
- Contractual, compliance, and operational processes should be addressed together.
- A file-based legal analysis should be carried out for the concrete situation.
Where to start with KVKK and GDPR compliance
The practical sequence is similar under both regimes. First, a data inventory: which personal data are processed, for which purposes, on which legal basis, and with which recipients. In Türkiye, for controllers that are subject to registration, this feeds the VERBİS filing; under the GDPR it feeds the record of processing activities. Second, the information layer: privacy notices for customers, employees and website visitors, aligned with the actual data flows. Third, the contract layer: data processing agreements with vendors and, for transfers abroad, the safeguards required by the Personal Data Protection Law (KVKK) and the GDPR.
Finally, compliance must be able to survive an incident: breach-response procedures built around the short statutory notification windows, a working process for data subject requests, and periodic training. A combined KVKK/GDPR compliance programme keeps the two regimes consistent instead of running two parallel projects.
The contract layer: processors and transfers
Once the inventory and the information-notice layer are in place, the contract layer follows: data processing clauses have to go into the agreements with suppliers acting as processors — the cloud provider, the call centre, the payroll and HR software, the marketing agency — the chain of sub-processors has to be made visible, and where data goes abroad the transfer safeguards the legislation provides for have to be chosen and documented. For controllers under a registration duty that same inventory is the basis of the VERBİS filing, and on the GDPR side of the record of processing activities — deriving both from one inventory rather than producing them separately cuts the cost and the risk of inconsistency at the same time.
Preparing for an incident
Compliance is tested in earnest at the moment of a breach. The short statutory notification windows mean the sequence has to be written down in advance: technical detection, legal assessment, notification to the authority and to the individuals concerned, and a record of each of those steps. Because the same incident is usually assessed under both regimes at once, the two notification flows belong in a single incident response plan rather than in two separate playbooks. Data subject requests need the same treatment: someone has to own the deadline.
Questions to ask internally
- Which data are processed, for what purpose and on which legal basis — and is explicit consent genuinely needed?
- Is a privacy notice shown on every channel through which data are collected?
- Which vendors have access to personal data, and do their contracts contain data terms?
- Do data leave the country, and if so, on which safeguard?
- Are retention and deletion periods actually run, or do they exist only in the policy?
- In the first hours of a breach, is it clear who decides?
The answers depend on the sector and on how processing is actually organised; the legislation in force and current regulator practice should be assessed file by file (as of July 2026).
Dual compliance on the Türkiye–Germany route
For Turkish companies with customers, a branch or a group company in Germany, both regimes apply to the same data flow at the same time. The most common failure is running two document sets — one for the KVKK, one for the GDPR — that never meet: one inventory, two sets of notices and a third reality in operations. A single process architecture closes that gap. For current developments on the data side, see our Data focus area.
Who owns compliance?
Data protection compliance slows down within the first quarter wherever no owner has been named. The model that works in practice is a small working group drawn from legal, IT and the business units, reporting to a single accountable person, with an annual review date in the calendar and a check step built into the process whenever a new product, channel or vendor is added. Once compliance stops being a project and becomes routine, its cost becomes predictable.
