The Law requires a compliance framework built on privacy notices, a legal basis, data security, VERBİS registration and data-subject requests. After 2024, cross-border transfers rest on three pillars: an adequacy decision, appropriate safeguards (including the standard contract — notified to the Board within 5 business days of signature) and incidental situations.
Overview
Law No. 6698 on the Protection of Personal Data sets the framework for the processing of personal data in Türkiye and is supervised by the Personal Data Protection Authority. Although inspired by the GDPR, it operates with its own institutions (VERBİS, Board decisions) and its own procedures.
The 2024 amendments
Law No. 7499, adopted in March 2024, fundamentally amended two areas. In the processing of special-category data, new legal bases, including employment-law obligations, were recognised. For cross-border transfers, a new three-tier regime replaced the old system, which had become blocked in practice: an adequacy decision; appropriate safeguards (binding corporate rules, a standard contract announced by the Board, a written undertaking); and limited incidental cases.
The most critical detail in practice
The standard contract must be notified to the Board within 5 business days of its signing; failure to notify is, in itself, grounds for an administrative penalty. In intra-group flows, contract inventory and notification tracking should be run from a single centre.
Core compliance scheme
Sound KVKK compliance consists of a processing inventory, a privacy-notice and consent architecture, a retention-and-destruction policy, VERBİS registration, data processor agreements, and a breach response plan. Employee data and marketing consents (İYS) are the areas that most frequently give rise to disputes.
Running it together with the GDPR
For companies with German connections, the most efficient approach is to combine KVKK and GDPR requirements into a single compliance scheme, and to build the transfer instruments in both directions (TR→EU, EU→TR) with the same set of contracts.
Penalties
The Law provides for administrative fines — updated each year at the revaluation rate — for breaches relating to the information obligation, data security, VERBİS, and Board decisions; with the 2024 amendments, failure to notify the standard contract within the time limit has also become a separate category of penalty. The Board may also resort to measures such as halting the processing and publishing its decisions.
Related content
For the EU side, read this together with the GDPR record. We address the compliance scheme in our Data focus area, and breach and incident response in our Cybersecurity focus area.
Official Sources
Statutory text · mevzuat.gov.tr KVKKBoard and guidelines · kvkk.gov.tr kvkk.gov.trCross-border transfer guide (No. 48) kvkk.gov.tr
