Pursuant to Article 16 of the Law No. 6698 on the Protection of Personal Data (“Law”), real or legal persons processing personal data must register with the Data Controllers’ Registry (tr. VERBIS) before processing personal data.
The Personal Data Protection Board (“Board“) evaluated the sector representatives’, certain public institutions’ and public professional organizations’ requests that, due to the COVID-19 outbreak, data controllers experience difficulties to duly fulfil VERBIS registration requirement. Accordingly, the Board extended the deadlines for VERBIS registration requirement.
Pursuant to the Board’s decision numbered 2021/238 and dated March 11, 2021, the Board extended the deadlines as below. Relevant announcement is available online here (in Turkish).
| Data Controllers | Start Date for VERBIS Registration Requirement | Previous Deadline | New Deadline |
| Real or legal person data controllers that have more than 50 employees in a year or an annual balance sheet above TRY 25 million (approx. USD 4 million) | 01.10.2018 | 30.09.2020 | 31.12.2021 |
| Data controllers residing outside of Turkey | 01.10.2018 | 30.09.2020 | 31.12.2021 |
| Real or legal person data controllers that have less than 50 employees in a year and an annual balance sheet below TRY 25 million (approx. USD 4 million), principle business activity of which is processing special categories of personal data | 01.01.2019 | 31.03.2021 | 31.12.2021 |
| State institutions and organizations | 01.04.2019 | 31.03.2021 | 31.12.2021 |
The relevant data controllers may review the Guidelines for Data Controllers’ Registry Information System for their registration processes. The guidelines are available here (in Turkish).
Conclusion
According to Article 18 of the Law, data controllers that fail to fulfill their VERBIS registration and notification obligations may be subject to administrative fines under the Law. In that regard, all relevant data controllers must complete their VERBIS registrations by the relevant deadlines above.
