KVKK advisory and compliance
A scope of services running from documents to practice.
Beyond ready-made texts, we take as our basis which data is processed, by whom, for what purpose and for how long. The work below is planned according to the need and the scope of the engagement.
- 01
Data inventory and risk analysis
Business units, data categories, processing purposes, legal grounds, recipients and retention periods are examined together. The roles of data controller and data processor are determined on the basis of actual decision-making and operational authority.
Work output: Data flow map, inventory and priority action list.
- 02
Privacy notice and explicit consent
Notices suited to employee, customer, visitor and candidate processes are prepared. Processing operations that require explicit consent are assessed separately; privacy notices and consent are not designed as texts that can be used in place of one another.
Work output: Process-specific texts, points of presentation and a record-keeping arrangement.
- 03
VERBİS and corporate policies
Whether a registration obligation or an exemption applies is assessed with regard to the Data Controllers’ Registry Information System (VERBİS). Consistency is established between the inventory, the registry declarations, and the retention and destruction policies.
Work output: Assessment of the obligation, and the necessary registry and policy work.
- 04
Transfers of data abroad
Data movements in cloud, email, customer relationship and support services are examined. The applicable transfer mechanism, the roles of the parties and the contractual and notification requirements are addressed together.
Work output: Transfer map, appropriate mechanism and a timeline of steps.
- 05
Employees and special categories of data
Personnel files, health and biometric data, and camera and access records are assessed. The condition for processing, proportionality, access authorizations and the retention arrangement are determined separately for each process.
Work output: Legal arrangements for human resources processes.
- 06
Website, cookies and digital tools
Forms, cookies, analytics, advertising and artificial intelligence tools are examined with regard to the data they collect and sharing with third parties. The aim is for the visible texts to match the preferences and data flows that the technical team actually implements.
Work output: Legal requirements list and implementation checks.
- 07
Supplier and data processing agreements
The responsibilities of service providers regarding instructions, confidentiality, security, subcontractors and breach notification are regulated. Audit, return of data and deletion/destruction at the end of the business relationship are reflected in the contract.
Work output: Data processing provisions, contract annexes and allocation of responsibility.
- 08
Applications, audits and disputes
Responses to data subject requests, the Board’s requests for information and documents, defenses and sanctions are assessed legally. Complaints, lawsuits and claims for damages are handled through the routes the specific case requires.
Work output: Application/response file and a dispute follow-up plan.