Pursuant to Article 16 of the Law No. 6698 on the Protection of Personal Data (“LPPD”), natural and legal persons who process personal data must be registered with the Data Controllers Registry prior to the processing of the data. With the regulation, the Board has been granted the right of discretion to make exceptions to the obligation to register with the registry.
What is the purpose of the Data Controllers Registry Information System?
With the relevant system, it is determined who the data controllers are within the scope of real and legal persons and it is a guiding tool within the scope of Personal Data Protection. In this context, a system that increases predictability has been created.
What kind of information is requested from real and legal persons during VERBIS registration?
Pursuant to paragraph 3 of Article 16 of the LPPD, those who wish to register with the Data Controllers Registry are required to make a notification including the following matters;
(a) Identity and address information of the data controller and its representative, if any.
(b) The purpose for which personal data will be processed.
- c) Explanations about the data subject groups and groups of persons and the data categories belonging to these persons.
ç) Recipients or recipient groups to whom personal data may be transferred.
- d) Personal data envisaged to be transferred to foreign countries.
- e) Measures taken regarding personal data security.
- f) The maximum period required for the purpose for which personal data are processed.
What are the Administrative Fine Amounts that may be Faced as a Result of Failure to Register with VERBIS?
Based on paragraph 18/1,ç of the Personal Data Protection Law No. 6698, the Personal Data Protection Board may impose administrative fines between 189.245 TL and 9.463.213 TL as the lower and upper limit to be valid in 2024. However, there have been instances in the past where fines were not imposed in cases where the data controller tried to complete the registration if the registration period exceeded by a few days. Such flexibility does not always apply and is entirely at the discretion of the administration.
In order to record this information correctly, it is necessary to contact experts in the field. We draw your attention to the fact that inventories made by someone who does not have sufficient knowledge of the LPPD may be inaccurate and this may lead to fines ranging from 36,053 TL to 1,802,626 TL.
Therefore, we remind you of the importance of making VERBIS Registration correctly and complying with the legal deadlines.
