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On 4 January 2022, the Turkish Personal Data Protection Authority (KVKK) issued a noticefor data controllers in relation to the obligation to register with the Data Controllers Registry Information System (VERBIS). The notice reminds data controllers that mere submission or mailing of the registration form is not sufficient to fulfil the registration obligation. The complete registration process also requires, among other things, the appointment of a 'contact person' for each controller, who must issue a notification linking them to the controller. The registration requirement applies to natural or legal persons which control data and either - have more than 50 employees per year or an annual financial balance of over TRY 25 million; - have less than 50 employees per year or an annual financial balance below TRY 25 million but pursue data processing as principal business activity; - reside outside of Turkiye; - are state institutions and organisations.
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