Obligation to Appoint a Data Controller Representative
The data controller representative is the person who has the duty and authority to carry out the works and transactions related to Data Controllers Registry (VERBİS), to communicate with data subjects regarding the applications or notifications and to carry out correspondence to be made with the Personal Data Protection Authority on behalf of the data controller residing abroad.
According to Article 11 of the Regulation on the Data Controllers Registry, which was published in the Official Gazette dated 30 December 2017 and numbered 30286 and entered into force on 01 January 2018; if the data controller is residing abroad, it is obliged to appoint a representative in Turkey. The appointed data controller representative must be a legal entity resident in Turkey or a Turkish citizen.
Data Controller Representation Services
As KPO+, we provide services related to determining and reporting the obligations of data controllers residing abroad within the scope of the Personal Data Protection Law No. 6698, preparing the necessary information and documents for the fulfilment of these obligations, VERBIS registration, correspondence with the Personal Data Protection Authority and responding to the applications to be made by the data subjects, with the information and approval of the data controllers residing abroad, and with the focus on the principle of transparency.
VERBIS Contact Person
The contact person is the real person notified by the data controller during the registration to the Data Controllers Registry (VERBİS) for communication with the Personal Data Protection Authority regarding the obligations of legal entities resident in Turkey and non-resident legal entity data controller representative within the scope of the Personal Data Protection Law and secondary regulations. The contact person is not authorised to represent the data controller in accordance with the provisions of the law and regulations, but is obliged to provide communication to respond to the requests of the data subjects to the data controller. In this context, the contact person primarily provides support on the following issues:
Notification or acceptance of notifications made by the Personal Data Protection Authority on behalf of the data controller
Forwarding the requests directed to the data controller by the Personal Data Protection Authority. Forwarding the response from the data controller to the Personal Data Protection Authority
Receiving the applications of the data subjects to the data controller under the first paragraph of Article 13 of the Law, on behalf of the data controller and forwarding them to the data controller, forwarding the response of the data controller to the data subjects
Completing tasks related to Data Controllers Registry (VERBİS) on behalf of the data controller