VERBIS, online registry system for personal data, is still waiting to be launched which was also regulated under the Law numbered 6698 about the Protection of Personal Data (“The Law”).
According to Article 16/2 of the Law, ‘Natural or legal persons who process personal data shall register with the Data Controllers Registry prior to commencing processing. However, considering objective criteria that shall be designated by the Board such as the characteristics and the number of data to be processed, whether or not data processing is based on any law, or whether data will be transferred to third parties, the Board may set forth exemptions to the obligation to register with the Data Controllers Registry.’
The Personal Data Protection Board (‘Board) has rendered a decision dated 19/07/2018 and numbered 2018/88 concerning the “Date of commencement of registration obligations” and announced the said on 18/08/2018.
According to this Board decision, after VERBIS is launched, the following will be obliged to register with the system within the prescribed time:
- The data controllers of natural or legal persons of which annual number of employees is more than 50 or an annual financial balance sheet total of more than TL 25 million will start to register on 01.10.2018 and will complete it in 12 months. Therefore they have time until 30.09.2019 for registration.
- The data controllers of natural or legal persons operated abroad will start to register on 01.10.2018 and will complete it in 12 months. Therefore they have time until 30.09.2019 for registration.
- The data controllers of natural or legal persons of which principal business activity is processing of special categories of personal data and annual number of employees is less than 50 and total annual financial balance is less than TL 25 million will start to register on 01.01.2019 and will complete it in 15 months. Therefore they have time until 31.03.2020 for registration.
- The data controllers of state institutions and organizations will start to register on 01.04.2019 and will complete it in 15 months. Therefore they have time until 30.06.2020 for registration.
Av. Derya Baksı
Stj. Av. Sinem İlikli
EYLÜL 2018
Tarlan Avukatlık Bürosu Bloğu 