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İTİMAT GLOBAL > Services > Personal Data Protection Service

ITIMAT GLOBAL CORPORATE NETWORK MANAGEMENT INC. 6698 PERSONAL DATA PROTECTION LAW COMPLIANCE AND APPLICATIONS SCOPE OF SERVICE

The following information text has been prepared regarding the determination of what needs to be done to harmonize the companies with the Personal Data Protection Law No. 6698 (“KVKK“),which was published in the Official Gazette dated 07.04.2016,and the scope of the service to be provided by us.

KVKK's Sanctions

The law imposes many obligations on those who process personal data and stipulates administrative fines of up to TL 1,802,640 to companies in case of noncompliance with the legislation or violation of the KVKK. We would like to point out that there is also a risk that prison sentences will be applied as there are also cases regulated as crimes in the Turkish Penal Code regarding personal data.

Obligations of the Data Controller in accordance with the KVKK

In accordance with the KVKK, the companies;

  • Fulfilling the disclosure obligation in accordance with the provisions of the Communiqué on the Procedures and Principles to be complied with in the Fulfillment of the KVKK and Lighting Obligation,
  • Registration of data controllers with an annual employee count of more than 50 and/or an annual balance sheet totaling more than 25 million Turkish Liras, except for the exceptions determined by the Personal Data Protection Board, in the Data Controllers Register (VERBİS),
  • To take all necessary technical and administrative measures to ensure the appropriate level of security in order to prevent unlawful processing of personal data, to prevent unlawful access to personal data, to ensure the protection of personal data,
  • If the persons concerned exercise their rights under Article 11 of the KVKK, they will respond to the applications within the period of time and fulfill the acceptable demands of the persons concerned,

Must. Companies that have an obligation to register with VERBİS must fulfill the registration obligation on the dates specified in the following summary table.

The purpose of this project is,

  • Creation of personal data inventory,
  • To evaluate the business and processes of the companies within the scope of the project in detail from legal and administrative perspectives and to carry out compliance analysis,
  • It is the determination of the necessary actions for KVKK compliance and their reporting to the company.

can be summarized.

Project Scope

Within the holistic approach, the project covers the following main topics.

  • Data inventory,
  • Legal Scope: Preparation of policies and procedures for the collection, processing, sharing and deletion of personal data, preparation of notification of disclosure obligation following the examination of personal data inventory and, where necessary, the creation of explicit consent texts, review and evaluation of all contracts of the company, especially employment contracts.
  • Scope for Administrative & Processes: Examination of methods and business processes related to the collection, processing, sharing and deletion of personal data, determination of requirements and needs and harmonization of processes with the law, evaluation and conclusion of requests, complaints, objections and other issues to be received by the person concerned or the Personal Data Protection Board within the scope of the KVKK, establishing policies, procedures and processes for compliance determination of competence requirements and responsibilities within ten.
Project Stages

The project consists of 3 stages, respectively:

Current Status Assessment:

  • Providing awareness training,
  • Data inventory,
  • Provision of legal documents,
  • To obtain information about the way of doing business and processes from the relevant business units – together with documentation and standards – and to analyze them in detail,
  • Obtaining information about organizational structure and analyzing competencies and requirements for organizational compliance

Improvement and Adaptation of Deficiencies:

  • Creating a personal data inventory by classifying the processed personal data in the light of the information obtained after the current situation analysis,
  • To determine the persons whose consent is required for the legal processing of data, to obtain the consent and to prepare the necessary texts for fulfilling the obligation of disclosure,
  • Preparation of revision proposals for contracts and other legal texts, preparation of revision proposals for forms and documents that may be subject to personal data processing,
  • Preparing in-house policies and regulations that include rules regarding the processing, storage, access and destruction of personal data,
  • Sharing data retention periods,
  • Preparation of new processes for the evaluation and conclusion of requests, complaints, objections and other issues to be received by the relevant person or the Institution/Board,
  • Preparation of policies and procedures regarding the expiration of the period requiring data processing or the storage period and/or deletion of data with the application of the data subject,
  • Preparation of the policy regarding the processing of personnel data,
  • Preparing the necessary consent for the processing of personnel data and any additional consents that may be required,
  • Completion of registration to VERBIS

Project Result:

  • Preparation and presentation of KVKK compliance and risk assessment analysis report with legal and administrative aspects
  • Making final revisions on KVKK Compliance and risk assessment reports and sharing them with the action plan
  • Organizing training on the new policy and operation regarding the KVKK compliance process./li>

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