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Data Protection Leader
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Volume: 15 Issue: 3
(March 2018)

subject access request data subject procedure data controller


Turkey: KVKK issues regulation to "consolidate SAR procedure"

The Turkish Personal Data Protection Authority (‘KVKK’) published, on 10 March 2018, a supplementary regulation (‘the Regulation’) to the Data Protection Law No. 6698 of 2016 (‘the Law’) in the Official Gazette, regarding the procedure to be followed by both data subjects and data controllers with respect to subject access requests (‘SARs’) under Article 11 of the Law.

Naz Değirmenci and Zeynep Ünlü, Associate Attorney and Senior Managing Counsel respectively at BTS & Partners, said, “The Regulation provides for a consolidated version of the provisions concerning the procedures to be followed by data controllers set forth under guidance documents issued by the KVKK. Organisations that have carefully undertaken their compliance projects are prepared; however, small and medium-sized companies are not aware of their obligations regarding the Regulation.”

In particular, the Regulation specifies the types of information that must be included by a data subject when submitting a SAR, the content to be provided by a data controller when responding, and establishes a time limit of 30 days for the data controller to respond to the SAR. 


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