A KVKK Compliance Roadmap for Companies

KVKK compliance is not a one-off paperwork exercise; it is an ongoing management discipline that touches every data-processing process in the company. The biggest mistake we see in practice is assuming compliance means merely adding a "privacy notice" to the website.

1. Build a Personal Data Inventory

Identify, department by department, what data you process, for what purpose, on which legal basis, to whom you transfer it and how long you retain it. The inventory is the foundation of every other step — privacy notices prepared without one do not reflect reality and turn into adverse evidence during an audit.

2. Separate Privacy Notices from Explicit Consent

The duty to inform applies to every processing activity; explicit consent is an exceptional basis to be used only where no other legal ground exists. Requesting consent for data that is necessary to perform a contract is a common mistake that renders the consent invalid.

3. Keep Your VERBIS Registration Current

Companies subject to the registration obligation must keep their VERBIS records consistent with their inventory. Failing to reflect operational changes in VERBIS increases the risk of administrative sanctions.

4. Review Your Data Processor Contracts

Cloud providers, payroll firms, courier companies: a data processing agreement should be in place with every supplier that processes your data, and where transfers abroad occur, one of the transfer mechanisms envisaged by the Board must be established.

5. Prepare a Breach Response Plan

A data controller that becomes aware of a breach must notify the Board within 72 hours. This clock runs even if the breach is discovered at the weekend. Meeting it is nearly impossible without a pre-agreed plan defining who decides and who drafts the notification.

Conclusion

We recommend treating compliance not as "do it once and forget it" but as a living system with periodic annual reviews. Our team supports every stage of the process, from inventory work to defences before the Board.

This article is for information purposes only and does not constitute legal advice. Contact our team about your specific situation.