On 27 December 2019, the Turkish Data Protection Board (“DPB”) announced the second postponement of the deadline for registration with the Data Controllers Registry Information System (VERBIS).
The deadlines for registering on VERBIS have been extended six months from the expiry date of each type of data controller. Information on previous deadlines can be found here.
The current deadline for registration with VERBIS for each group of data controller is as follows:
As such, for data controllers already registered with VERBIS, it would be advisable to review their existing data privacy documents (specifically the data inventory) and policies prepared to this effect and ensure that the information submitted to VERBIS is in line with such documentation.While the DPB has granted an extension for data controllers for registration with VERBIS, it has also stated that there have been many inconsistencies with the VERBIS registrations already received. Specifically, the DPB has stated that the information submitted to VERBIS is inconsistent with the personal data inventory of the data controller in question.
As for the data controllers that have not yet registered with VERBIS, it would be advisable to prepare the relevant documentation strictly in compliance with the applicable legislation and in a manner that reflects the data privacy practices of such data controller and ensures that the information submitted to VERBIS is consistent with the said documentation and policies.