Sustainable KVKK and GDPR Compliance in a Data-Driven World
Personal data protection is not a one-time project, but a living process. Every new employee, every new system integration, every new customer relationship reshapes your data protection obligations.
With 2024-2025 regulatory changes, we see the "Explicit Consent" era closing and the "Standard Contracts" era beginning. Every company using cloud services, email systems, and CRM software is now subject to new obligations for international data transfer. Rona Legal manages the entire process from VERBİS registration to GDPR compliance, data breach management to standard contract signing.
⚠️ 2025 International Data Transfer Reform
Most companies transfer personal data abroad without treating it as a transfer, simply by using cloud email, storage and CRM services hosted outside Turkey. Where that is the case, the transfer needs a lawful basis under the cross-border transfer rules — for many organisations, a standard contract published by the KVKK Board.
Standard Contracts (SCCs)
Data transfer to overseas servers (Cloud/Email) now mandatorily requires signing standard contracts published by the KVKK Board.
📋 Contract modules: Distinguish between "Controller to Controller" and "Controller to Processor."
5 Business Day Rule
Signed contracts must be notified to the KVKK Board within 5 business days.
💰 2025 penalties for non-notification: ₺50,000 - ₺1,000,000
Worth checking: if your organisation uses cloud services hosted abroad and has not put a lawful transfer basis in place, that is a gap to close. Whether a given service actually involves a cross-border transfer depends on where the data is processed and on the contractual arrangement, so it is assessed service by service rather than assumed.
Our Comprehensive Services
VERBİS Consulting
Analysis of Data Controllers Registry Information System (VERBİS) registration obligation, inventory preparation, and maintenance.
Registration obligation analysis and inventory preparation
VERBİS registration update and monitoring
Protection against increasing VERBİS penalties for 2025
⚠️ 2025 Penalty Amounts: Failure to comply with VERBİS registration: ₺272,380 - ₺13,620,402
GDPR (General Data Protection Regulation) Compliance
GDPR compliance consulting for Turkish companies offering goods or services to the EU market or processing EU citizen data.
GDPR check-up for exporting companies
EU Representative appointment services
Preventive law against GDPR non-compliance penalties (4% of global revenue)
Process-Specific Information Notices
Preparation of legal texts specific to employee, customer, visitor, and supplier processes instead of standard documents.
Job candidate and personnel information notices
Customer and visitor information forms
Supplier and business partner data processing agreements
Data Breach Management
Emergency response and legal process management in case of cyber attacks, unauthorized access, or data leaks.
Notification to KVKK Board within 72 hours
Fulfillment of notification obligation to data subjects
Crisis management and reputation protection strategies
Frequently Asked Questions
❓ What is the penalty for not registering with VERBİS?
According to 2025 revaluation rates, the penalty for failure to comply with VERBİS registration obligation ranges from ₺272,380 to ₺13,620,402.
💡 Rona Legal Warning: Registration obligation is not only for "large companies." Every company with more than 50 employees or whose main activity involves personal data processing must register with VERBİS.
❓ Does using Gmail or AWS count as data transfer?
Yes, using services with servers located abroad constitutes "International Data Transfer" and requires signing a Standard Contract according to the new regulation.
💡 Scope: All cloud services including Google Workspace, Microsoft 365, AWS, Azure, Salesforce, HubSpot, Mailchimp are covered.
❓ Is KVKK compliance only the IT department's responsibility?
No. KVKK compliance is an organizational responsibility. Every department that processes personal data—HR, Sales, Marketing, Logistics—is part of the compliance process.
💡 Rona Legal Solution: We prepare training covering all departments, process maps, and responsibility matrices.
Don't Let Data Penalties Darken Your Company's Future
Manage your KVKK and GDPR compliance process with proactive legal consulting. Contact us for VERBİS registration, standard contracts, data breach management, and continuous compliance monitoring.
Frequently asked questions
Does using a foreign cloud service count as transferring data abroad?
Often yes, but it is assessed service by service. What matters is where the personal data is actually processed and stored and what the contractual arrangement provides — not the brand name of the service. Cloud email, storage, CRM and marketing platforms are the usual candidates.
What replaced explicit consent for cross-border transfers?
Standard contracts published by the KVKK Board have become the principal route for many organisations, in place of relying on explicit consent for routine, systematic transfers. Consent was never designed to carry ongoing operational transfers.
Which standard contract module applies to us?
It depends on the roles of the two sides. The modules distinguish controller-to-controller from controller-to-processor arrangements, and picking the wrong module means the transfer is not properly covered. Mapping the roles correctly is the first step.
Does the signed contract have to be notified to the Board?
Yes. Signed standard contracts must be notified to the KVKK Board within five business days. Missing that window is a separate breach from the transfer itself.
What is VERBİS and do we have to register?
VERBİS is the Data Controllers Registry Information System. Whether registration is obligatory depends on criteria such as the nature and volume of processing and the size of the organisation, so the first step is an obligation analysis rather than a default registration. Where the duty applies, the inventory has to be prepared and then kept up to date.
Are the penalty amounts fixed?
No. Administrative fine bands under the Turkish regime are revalued each year, and the applicable figures depend on the year of the breach. Any amount quoted on a web page should be confirmed against the current tariff before it is relied on.
Do we need both KVKK and GDPR compliance?
If you process the personal data of people in the EU in connection with offering goods or services to them or monitoring their behaviour, the GDPR can apply alongside the Turkish regime. The two are similar in structure but not identical, and a single compliance file has to satisfy both where both apply.
Is compliance a one-off project?
No. Every new employee, system integration and customer relationship reshapes the data map. The inventory, the transfer bases and the retention periods have to be revisited as the organisation changes, which is why compliance is maintained rather than completed.
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