Typical gaps: an EU representative (Art. 27), the data protection impact assessment (DPIA), a different breach notification regime, and transfer tools. We run your existing structure through the GDPR threshold and close only the gaps.
The lawful-basis architecture also differs, though not by absence: the KVKK has its own legitimate-interest ground in Article 5(2)(f), but it is drawn more narrowly — conditioned on not harming the data subject’s fundamental rights and freedoms — and is read more restrictively in practice, which changes how marketing, HR and analytics are justified. We re-map each processing activity to a valid GDPR basis rather than assuming the KVKK grounds carry over unchanged.
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