Services Comparison
See how data protection requirements differ across Turkey, the EU, the UK, and Switzerland — all in one place. Find the right services for your compliance needs.
Turkey
KVKK
State registration (VERBİS) required
EU
GDPR
Strictest cookie consent — full opt-in
UK
UK GDPR
Separate post-Brexit representative
Switzerland
nFADP
Personal fines on individuals, not companies
Full Service Comparison
| Service Area | 🇹🇷TurkeyKVKK | 🇪🇺European UnionEU GDPR | 🇬🇧United KingdomUK GDPR | 🇨🇭SwitzerlandnFADP |
|---|---|---|---|---|
🏛️Legal Representative Obligation | Data Controller RepresentativeKVKK — Law No. 6698 A representative appointed by foreign companies processing personal data in Turkey. Required for non-resident data controllers to comply with KVKK obligations. | EU RepresentativeGDPR — Article 27 A legal point of contact appointed by non-EU companies that process EU residents' personal data. Required under Article 27 to serve as the bridge between your organization and EU supervisory authorities. | UK RepresentativeUK GDPR — Article 27 A contact appointed by non-UK companies for London/UK. Serves as the official point of contact for the ICO (Information Commissioner's Office) and UK-based data subjects. | Swiss RepresentativenFADP — Article 14 A representative appointed by non-Swiss companies in certain risk scenarios. Required under the new Federal Act on Data Protection for organizations processing Swiss residents' data at scale. |
📋Data Inventory / Official Registration | VERBİS RegistrationKVKK — Data Controllers Registry Mandatory online registration and data inventory upload to Turkey's central state system (VERBİS). All qualifying data controllers must register before processing personal data. | ROPA (Record of Processing Activities)GDPR — Article 30 A mandatory internal digital inventory documenting all processing activities. No state registration required — the ROPA must be maintained internally and produced on request to supervisory authorities. | ROPA (Record of Processing Activities)UK GDPR — Article 30 An internal digital inventory of all data processing activities. No state registration required — maintained internally and produced on request to the ICO. | Data Processing RegisternFADP — Article 12 An internal data processing inventory maintained by the controller. SMEs with fewer than 250 employees may be exempt unless high-risk processing is involved. |
📄User Information Notice | Clarification Text (Aydınlatma Metni)KVKK — Article 10 A mandatory disclosure text explaining to data subjects why and how their personal data is processed, the legal basis, recipients, and their rights under Turkish law. | Privacy NoticeGDPR — Articles 13–14 A detailed privacy policy compliant with GDPR transparency requirements. Must include information about your EU Representative, DPO details, legal bases, data retention, and cross-border transfers. | Privacy NoticeUK GDPR & DPA 2018 A comprehensive privacy notice fully compliant with UK data protection law and ICO (Information Commissioner's Office) guidance and standards. | Privacy Statement (Datenschutzerklärung)nFADP — Transparency Obligations A comprehensive privacy statement compliant with Swiss law, including cross-border data transfer rules and the specific requirements of the new Federal Act on Data Protection. |
🍪Cookie Consent Management | Explicit Consent / NotificationKVKK — Board Guidance Cookie consent management aligned with Turkish Data Protection Board guidance. Operates per explicit consent principles with an opt-out (refusal) link commonly offered to users. | Cookie Consent — Strict Opt-inGDPR + ePrivacy Directive Very strict cookie consent management. No marketing or analytics cookies may run in the background before the user explicitly clicks "Accept". Full opt-in required before any non-essential tracking. | Cookie Consent — Strict Opt-inUK PECR + UK GDPR Strict cookie consent under UK PECR (Privacy and Electronic Communications Regulations). Tracking cookies cannot fire without prior explicit user consent. | Cookie Consent — Notice & Opt-outnFADP + Swiss Telecommunications Act More flexible than the EU model. Informing the user about cookie usage and offering an easy opt-out (refusal) option is sufficient for compliance under Swiss law. |
⚖️Administrative Fine Ceiling | Administrative Fine CeilingKVKK — Administrative Penalties Fixed TRY fines revalued annually (in the millions of TRY). Fines apply per infringement category and are adjusted each year for inflation. | Administrative Fine CeilingGDPR — Article 83 Up to 4% of global annual turnover or €20 million, whichever is higher. The most severe fining regime in data protection law worldwide. | Administrative Fine CeilingUK GDPR — ICO Enforcement Up to 4% of global annual turnover or £17.5 million, whichever is higher. Enforced by the Information Commissioner's Office (ICO). | Administrative Fine CeilingnFADP — Article 60 et seq. Personal fine of up to CHF 250,000 levied on the responsible individual (typically a manager or officer), not the company. A uniquely personal liability regime. |
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