With the decision dated March 11, 2021 and numbered 2021/238 by the Personal Data Protection Board within the Personal Data Protection Authority (“PDPA”), the deadline set for the obligation to register in the Data Controllers Registry (“VERBİS”) for the data controllers, which was previously extended more than once, has been extended.
In this context, based on the grouping made separately for data controllers, the last registration obligation dates, which were decided as 30 September 2020 and 31 March 2021, have been changed as follows:
| DATA CONTROLLER | REGISTRATION PERIOD FOR DATA CONTOLLERS REGISTRY |
| Real and legal persons who are controlling data who have more than 50 employees OR an annual balance sheet total of more than 25 million TRY
|
31/12/2021 |
| Real and legal persons who are controlling data and who are residing abroad
|
31/12/2021 |
| Real and legal persons who are controlling and processing sensitive (special categories of) data but having less than 50 employees AND an annual balance sheet total of less than 25 million TRY
|
31/12/2021 |
| Public institutions and organizations | 31/12/2021 |
The extension of the registration deadline, which was previously extended more than once, was justified by the fact that data controllers in the COVID-19 process made a request from the PDPA as a result of difficulties.
It is estimated that the extension made by the institution more than once after the sending of warnings in such a way as to give the data controllers time to register, may create negative impact in terms of compliance with the legislation.
Our article on VERBIS registration obligation dated September 13, 2019 can be accessed here.
The full text of the “Announcement on Extension of Registration Period to Data Controllers’ Registry” dated March 11, 2021 and numbered 2021/238 can be accessed here.
You can access the in-office training presentation on Personal Data Protection Law held by our office here.
You can contact us for further information and to take advantage of our advocacy and consulting services. You can find detailed information about our office’s work on Information Technology Law, Corporate Law and Consumer Law on our website.
Adar UÇAR (Attorney at Law)
