Guides

How to Run a KVKK Compliance Check

Non-compliance with KVKK (Turkey's Law on the Protection of Personal Data) is a risk most companies only notice once an audit or a complaint arrives. Administrative fines can run into the millions, but the real exposure usually shows up before the fine: not knowing what to do during a data breach, or having no process for a customer's "delete my data" request.

The 9 points below let you assess your own KVKK compliance quickly. Each one is among the first questions a real audit asks.

1. Are You Registered with VERBİS?

Companies above certain revenue/employee thresholds are required to register with the Data Controllers' Registry (VERBİS). Even below that threshold, you should clearly know which categories of personal data you process.

2. Are Your Disclosure Notices Up to Date?

Customers and employees need a clear notice explaining which of their data you process, for what purpose, and for how long. Having one "somewhere" isn't enough — it needs to reflect current regulation.

3. Do You Have a Personal Data Processing Inventory?

An inventory of which system holds which personal data, who can access it, and how long it's retained underpins both your VERBİS registration and a fast response during a breach. Without it, you can't answer "what data leaked?" within minutes.

4. Do You Know What to Do If a Data Breach Happens?

KVKK requires a breach to be reported to the Board and affected individuals within a set window. Without a written, tested action plan, this process gets improvised in a panic — and usually runs late.

5. Do You Transfer Data Abroad?

Cloud storage, email marketing tools, AI services — many everyday tools process data on servers outside Turkey. That's not a problem by itself, but you need to know whether KVKK's cross-border transfer requirements (explicit consent, adequacy decision, standard contractual clauses) are actually met.

6. Do You Have Data Processing Agreements with Vendors?

Your accountant, your courier, your cloud provider — every third party with access to personal data should be under a signed data processing agreement (DPA). Otherwise, their breach becomes your liability.

7. Do You Have a Retention and Destruction Policy?

KVKK requires personal data to be deleted or anonymized once its processing purpose no longer applies. "We keep it indefinitely" isn't a compliance strategy — it's a standing risk.

8. Have Your Employees Had KVKK Awareness Training?

The most common cause of a breach isn't malice — it's a customer list accidentally dropped into a public spreadsheet. Short, regular training removes most of this risk.

9. Are Your Technical Security Measures Sufficient?

Encryption, access control, regular backups — these basic technical measures are both part of KVKK's data security obligation and your strongest defense if a breach does occur.

Instead of Checking Each Point by Hand

Hukuk Check-up's structured scan — covering KVKK and 7 other legal domains — turns this checklist into a structured report for you, so you have a concrete risk map before you go to a lawyer.