Outsourced KVKK
Advisor & Contact Person
Continuous elite legal oversight for your Turkish operations. Leverage our 30+ years of legal authority to manage your "İrtibat Kişisi" duties, conduct ongoing audits, and keep your enterprise insulated from KVKK Board fines.
The Need for Continuous Oversight in Turkey
Unlike the EU GDPR, the Turkish KVKK does not explicitly mandate a formal "Data Protection Officer" role. However, the regulatory reality of operating in Turkey makes continuous, expert oversight an absolute necessity.
The KVKK Board issues new summary decisions continuously, shifting the interpretation of explicit consent, cookie usage, and HR data processing. Furthermore, your VERBİS registration must be updated within 7 days of any operational change. Treating KVKK compliance as a "one-time project" guarantees that within six months, your documentation will be obsolete, and your organization will be exposed to Article 18 administrative fines.
Statutory Framework: The Contact Person (İrtibat Kişisi)
Relevant Turkish Legislation
- Regulation on the Data Controllers Registry, Article 11:
Requires legal persons established in Turkey to assign a "Contact Person" (İrtibat Kişisi) during VERBİS registration. This person acts as the communication link with the Authority. - KVKK Law No. 6698, Article 12: Security of Processing
The ongoing mandate to ensure data security requires constant technical and administrative monitoring, a task best suited for an external advisory team.
Our Outsourced Advisory Model
We operate as the legal engine behind your internal compliance team. If you are a Turkish company, you assign a trusted internal employee as the Contact Person; we then act as their direct legal counsel, ensuring every action they take is backed by 30+ years of legal authority.
Continuous VERBİS Management
We monitor your operations and execute the mandatory updates to your Data Inventory and VERBİS registry, ensuring you never miss the 7-day statutory deadline.
Data Subject Request (DSR) Execution
When citizens submit requests under Article 11, we advise your team on how to verify, process, and legally respond to the requests within the 30-day limit.
Vendor & Product Triage
Before your IT team buys new software, or marketing launches a campaign, our legal engineers review the proposal to ensure Data Protection by Design.
Is Your Compliance Decaying?
Secure a highly qualified, legally robust advisory team without the recruiting delays or payroll overhead of hiring an internal privacy lawyer.
Discuss Advisory RetainersFrequently Asked Questions
Clarifying continuous compliance obligations in Turkey.
Does the Turkish KVKK mandate a Data Protection Officer (DPO)?
Unlike Article 37 of the EU GDPR, the Turkish KVKK does not explicitly use the term 'Data Protection Officer' nor does it formally mandate one in the same manner. However, it requires the establishment of a 'Contact Person' (İrtibat Kişisi) and heavily implies the need for a Data Protection Committee (KVK Komitesi) to ensure continuous Article 12 compliance.
What is the role of the 'İrtibat Kişisi' (Contact Person)?
The Contact Person is the individual designated in the VERBİS registry by Turkish companies. They are the communication channel between the Data Controller and the KVKK Authority, and they handle requests from data subjects. The Contact Person must be a Turkish citizen.
Can an outsourced firm act as our Contact Person?
A legal entity (like a law firm) cannot be the 'Contact Person' in VERBİS; it must be a natural person. However, organizations commonly designate an internal employee as the Contact Person while retaining our firm as the 'Outsourced DPO/Advisor' to actively manage, train, and instruct that employee on all legal matters.
What is the difference between a Representative and a Contact Person?
Foreign companies appoint a 'Data Controller Representative' (Veri Sorumlusu Temsilcisi) which CAN be a legal entity (our firm). Domestic Turkish companies appoint a 'Contact Person' (İrtibat Kişisi) who must be a natural person.
Why do we need DPO-as-a-Service in Turkey if it's not legally mandated?
Compliance is not a one-time project. VERBİS must be updated every 7 days when changes occur. Board precedents constantly evolve. Without continuous expert oversight, your compliance framework degrades, exposing you to massive administrative fines under Article 18. Outsourcing this provides elite legal protection without the overhead of an internal legal team.
If the outsourced advisor makes a mistake, who is liable?
Under the KVKK, the Data Controller retains full administrative liability for fines issued by the Board. However, as an outsourced legal service, we provide professional indemnity and expert defense, unlike an internal employee.
Secure Elite Legal Oversight Today
Stop treating compliance as a one-time project. Mandate our senior Turkish attorneys to provide continuous advisory services and protect your enterprise.
Request Advisory ProposalDisclaimer: This content is for informational purposes only and does not constitute legal advice or create an attorney-client relationship. Turkish data protection regulations (Law No. 6698) and Board precedents are subject to change. Please consult directly with our legal team for tailored counsel.