Compliance with KVKK and GDPR in a single framework, ready for audit.

One programme, two bodies of legislation

Every company operating in Türkiye and touching the EU market is effectively subject to two data protection regimes at once: KVKK and GDPR. Keeping two separate compliance folders is both costly and risky; a single programme built with the differences in mind (representative, DPIA, notification deadlines, transfer mechanisms) provides a defence with the same file in both audits.

The most common cause of death for data compliance is the project ending and the folder being shelved. A new CRM, a new campaign, a new HR tool — each one makes the inventory obsolete. We build the programme with an annual maintenance rhythm (updating the inventory, revising documents, refreshing training, running drills) and leave behind a “data check-up” routine that catches changes.

A single programme depends on managing the differences deliberately. On the GDPR side, controllers not established in the EU must appoint a representative, and high-risk processing calls for a data protection impact assessment (DPIA); the KVKK has no exact equivalent of either, but it carries its own registration requirement and, since 2024, transfer notification obligations. On a breach, against the 72-hour window in Article 33 GDPR, Article 12 KVKK says “as soon as possible” — and the Board’s practice takes 72 hours as the benchmark. The enforcement architecture differs too: the GDPR works with turnover-linked caps, the KVKK with tiered administrative fines. The programme reduces these differences to a single checklist, with every line showing which regime each step comes from.