Client Alert:

FINAL WARNING AND TIME EXTENSION FOR DATA CONTROLLERS TO COMPLY WITH REGISTRATION OBLIGATIONS

FINAL WARNING AND TIME EXTENSION FOR DATA CONTROLLERS TO COMPLY WITH REGISTRATION OBLIGATIONS

This article is one of many articles we have published in relation to the legal implications of Covid-19. Please click here for our “Covid-19 Insights” page and other articles.

Having identified that some of the data controllers have not been able to complete their registration with VERBIS (i.e. the data controllers’ registry) due to Covid-19 related reasons, the Personal Data Protection Board (“Board”) granted a de facto time extension to the data controllers for fulfilling their registration obligations. The decision no. 2020/760 and dated 1 September 2020 (“Decision”) on the “extension” was announced on the Board’s website yesterday.

According to the Decision, the Board will serve a written notification to the data controllers that have not fulfilled the registration requirements before the deadline of 30 September 2020. These data controllers will be obliged to complete their registration with VERBIS within the period specified in the written notification. Thus, although the term for registration with VERBIS has already expired, the data controllers will be warned by the Board one last time and will be granted an additional extension before an administrative fine is imposed on them.

Although it is not explicitly specified in the Decision whether the extension will cover foreign data controllers, taking into account that the Board refers to the thresholds for the requirement of registration that apply for controllers residing in Turkey, it may be inferred that the extension will only be applicable for data controllers residing in Turkey. Having said that, the Board may detail its decision in the forthcoming days and provide for an equal extension for the foreign data controllers. We will keep our clients updated on any developments regarding the matter.

You may find further details of the registration obligations in one of our earlier articles here. Please do not hesitate to contact our data protection team at dataprotection@ersoybilghean.com for any questions you may have regarding this matter.

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