Building a single compliance programme for KVKK and GDPR
For a client operating in the Turkish and EU markets, a single compliance programme was built spanning from the data inventory to the privacy notice set, and from cross-border transfer mechanisms to the breach response plan; a structure defensible with the same file in both audits was the goal.
Two legal regimes, one operation, scattered files
The group companies processed the same customer and employee data in processes subject to two bodies of legislation; compliance efforts run separately had produced conflicting texts.
The goal was a single programme built with awareness of the differences (representative, DPIA, notification, transfer mechanisms) and a living maintenance rhythm.
Our Approach
Keeping the commercial objective at the centre, we broke the legal risks into measurable steps.
01 · Inventory
Processing activities were consolidated into a single record in the language of both bodies of legislation; the legal bases and retention periods were clarified.
02 · Document Set
The privacy notice, consent, policy, and VERBİS (Turkish data controllers' registry) content was aligned with the reality of operations.
03 · Transfer & Breach
Standard contractual clauses and a notification regime were put in place; the 72-hour plan was tested through a drill.
Timeline
The main stages of the process.
A structure defensible with a single file in both audits
The programme was completed with the inventory, document set, transfer mechanisms and breach plan; compliance was handed over not as a one-off project but as an order with a maintenance rhythm.
- One inventory, two regulatory languages
- A text set aligned with operations
- Transfer mechanisms and a notification regime
- A breach plan tested through a drill
Services Involved in This Matter
Planning a similar transaction? Explore the services we provided in this matter.
Related Areas of Expertise
The practice and focus areas engaged on this matter.
Sectors
The sectors in which we most frequently advise on matters of this kind.
Technology
Legal advisory on licensing, SaaS, data, intellectual property, investment, scaling, compliance, and product law for technology companies.
Explore →Export & Import
Advisory for the sales, delivery, payment, customs, distributorship, collection, and cross-border dispute processes of foreign trade.
Explore →Related Publications
Our insights and guides related to this matter.
The Team on This Matter
Our multilingual team handling the matter.
Related Matters
A selection of similar transactional and advisory matters.
Uninterrupted legal counsel for a multinational supplier
Retainer-based support across day-to-day commercial operations, contract management and compliance processes.
Designing corporate governance across group companies
Single-source management and documentation of general assembly, board and compliance processes.
Data breach response and notification management
Managing detection, legal assessment, authority notifications, and communications from a single plan when a system breach is suspected.
First we clarify the commercial objective, risk appetite, timeline, and decision-maker needs. We then break the work into legal analysis, document/contract structure, and implementation steps, and manage the process through a single point of contact.
Because of the attorney's professional duty of confidentiality and client privacy, matters are anonymised. In a meeting, within the limits of confidentiality, we can describe our comparable experience more concretely.
In a short preliminary meeting, we take in the objective, the existing documents, the parties, the time pressure, and the critical risks. We then clarify the scope, team, timeline, and fee model.
To complete a similar matter with confidence.
Let us manage your process from start to finish with our experience in similar cases.