REGISTRATION DATES FOR DATA CONTROLLER REGISTRY (VERBIS)

In the scope of Law on The Protection of Personal Data numbered 6698 (the “Law”), the Data Protection Authority in Turkey (the “Authority”) has announced the registration dates for data controller registry (“VERBIS”) as follows:

  • The starting date on record to VERBIS for
  • Data Controllers that have the average annual number of employees more than 50 employees or yearly financial balance sheet total of more than TL 25 million, and
  • Data controllers resident abroad, is October 1, 2018. These data controllers may apply to VERBIS until the date of 30.09.2019 for registration.

 

  • The starting date on record to VERBIS for Data Controllers that have the average annual number of employees less than 50 employees and the main activity is the processing of special categories of personal data, is January 1, 2019. These data controllers may apply to VERBIS until the date of March 31, 2020 for registration.

 

**** Therefore, it is underlined that the scope of this Article is limited to the data controllers that process only special categories of personal data in terms of their main activities. i.e.; hospitals, health clinics including dental clinics, laboratories, etc.

 

  • The starting date on record to VERBIS for public institutions and organizations that are data controllers is April 1, 2019. These data controllers may apply to VERBIS until the date of June 30, 2020 for registration.

 

At this point, it is important to note that some data controllers stated below are not obliged to register in VERBIS:

  • Their main activity is not the processing of special categories of personal data, and,
  • Data Controllers that have the average annual number of employees less than 50 employees,  and,
  • Data Controllers that yearly financial balance sheet total of less than TL 25 million.

 

Moreover, some other data controllers are not obliged to register in VERBIS as stated below:

  • Data Controllers that process personal data only through non- automated means, provided that it is a part of any data recording system,
  • Notaries,
  • Associations, Foundations, Trade Unions (limited only to data processing activities for their members, employees, relatives and donators),
  • Political parties,
  • Attorneys at law,
  • Independent accountant and financial advisor and certified public accountants,
  • Mediators and,
  • Customs brokers.

 

As we have indicated in our previous publications, the data controllers exempted from VERBIS, shall continue to fulfil other obligations (i.e. keeping personal data processing inventory, preparing personal data storage and destruction policy, etc.) imposed on it by the relevant legislation.

 

Regards,

CELIKBAS LAW OFFICE