Cybersecurity
Law

Legal Cyber Risk Mapping

The organization’s business model, critical services, data types, information assets, suppliers and applicable regulations are examined together. Existing controls are assessed not only by the existence of documents but by actual practice and allocation of responsibility; a priority and responsibility matrix is prepared for high-impact weaknesses.

Corporate Cyber Governance Model

The duties of the board of directors, senior management, legal, information security, information technology, risk, internal audit, human resources and communications units are defined in writing. Decision, reporting and escalation flows are adapted to the organization’s existing management structure.

Board and Senior Management Oversight Processes

Cyber risk is brought onto the management agenda; a periodic indicator set, critical incident thresholds, a record of investment decisions and follow-up of corrective actions are structured. Oversight responsibility is examined in terms of the Turkish Commercial Code, sector regulations and the internal authority structure of the company.

Cybersecurity Policy and Procedure Architecture

A hierarchy is established among the top-level policy, acceptable use, access, log management, incident response, backup, supplier security, vulnerability management and business continuity documents. It is ensured that the documents do not contradict each other or actual technical practice.

Information Security, Confidentiality and Role Allocation

Overlapping or unassigned duties among the information security manager, technical operations, data protection officers, legal and internal audit are identified. The role matrix, job descriptions and incident response plan use the same terminology.

Basis: Law No. 7545 · KVKK data security

Scope and Obligations Analysis under Law No. 7545

The organization’s position under the Law is determined by criteria such as service provision, data processing, connection to critical infrastructure, activity in the field of cybersecurity and supply of products. Information provision, taking measures, incident notification, inspection, certification and transitional provisions are reviewed together with current regulations.

Legal Structuring of National Cyber Incident Response Center (USOM) and SOME Processes

The corporate or sector-based SOME obligation, contact persons, notification procedure and internal authority flow are examined. It is clearly set out that the technical team and the legal unit bear different responsibilities for the content of a notification. Taking into account that reports and security content submitted through USOM are being transferred to the Cyber Security Presidency (Siber Güvenlik Başkanlığı) address, the current addressee and channel are verified.

Critical Infrastructure and Critical Service Obligations

Services, assets and supply dependencies that are considered critical are identified. A compliance plan is prepared for continuity, testing, audit, product procurement, incident reporting and access authorizations under the specific regulations.

Sector-Specific Cybersecurity Regulation Analysis

Information system provisions in electronic communications, banking, payment and electronic money, capital markets, energy, health, insurance and other regulated activities are recorded in a separate obligations table. A general cybersecurity plan cannot make a sector’s specific rule invisible.

Basis: Law No. 7545 · 2026 duty amendments · Current reporting and information channel · Banking regulations · Payment services regulations

Legal Review of the Cyber Incident Response Plan

The intake, classification, technical containment, decision authority, notification, communication, record keeping and closing stages of an incident are reviewed. The plan is structured to cover weekend, night, supplier-caused incident and unreachable-manager scenarios.

Incident Classification and Severity Matrix

Vulnerability, suspicious activity, confirmed incident, personal data breach and critical service interruption are defined with separate thresholds. A repeatable decision structure is built on criteria such as confidentiality, integrity, availability, number of persons, nature of data, spread and reputational impact.

Legal Support for the Cyber Incident Crisis Desk

During an active incident, the legal decision flow, meeting minutes, notification timeline, contract review and management reporting are managed in a single file. A legal opinion does not replace technical findings; decisions are based on verified technical data.

Immediate Legal Assessment in the First Stage of an Incident

Through engagement and availability confirmation, the incident owner, authorized decision-maker, technical team and secure communication channel are identified. Urgent measures, preservation of records, notification deadlines, calls to external service providers and the initial management note are tracked on the same checklist. Planning for the first 24 hours of an incident does not mean round-the-clock on-duty service by the firm or a commitment to intervene at a specific time.

Basis: Law No. 7545 · KVKK breach notification

Notification, Reporting and Communication Matrix

Separate assessment columns are set up for the Cyber Security Presidency, the relevant sector regulator, the Personal Data Protection Board, judicial authorities, insurers, contract parties and data subjects. The deadline, starting point, responsible person, approving authority and channel to be used are recorded.

KVKK and Personal Data Breach Management

The effect of the cyber incident on personal data, the roles of data controller and data processor, and the conditions for notifying the Board and data subjects are assessed separately. The moment of learning is recorded; the notification deadline is not postponed while awaiting a final digital forensics report. The processor’s duty to inform the data controller without delay is also monitored separately.

Legal Review of Technical and Administrative Data Security Measures

The relationship of access control, log monitoring, authorization review, backup, encryption, staff training, supplier audits and retention practices with the legislation is assessed. Technical adequacy testing is carried out by the competent technical team; the firm manages the obligation, liability and record aspects.

Preparation of Regulatory Notifications

Whether a notification obligation has arisen, the start of the deadline, minimum content and the possibility of phased information are verified. Definitive results not yet verified are avoided in the initial notification; responsibility and a calendar are set for follow-up notifications and the closing report.

Communication with Data Subjects, Customers and Contract Parties

The legal basis, target audience, content and timing of communication are determined according to the risk of the incident. The statement provides the information needed for individuals to protect themselves without unnecessarily disclosing the investigation, system security or trade secrets. Notification to the Board, notification to affected persons and contractual notification to customers are recorded as separate procedures.

Basis: KVKK breach notification · Notification to data subjects · KVKK data security

Preservation of Digital Records and Examination Instructions

It is determined which team will preserve logs, disk images, emails, authentication records, alarms, tickets and communication records and how. Written instructions are prepared to ensure the original source is not altered, accesses are recorded and technical examination copies are separated.

Legal Coordination of Digital Forensics Work

The scope, authority, confidentiality, output format and delivery method of the competent technical service provider are determined by contract. The impact of the examination on personal data, employee privacy, trade secrets and possible criminal investigations is managed from a legal perspective.

Internal Cyber Incident Review

While examining the cause of the incident, control weaknesses, neglect of duties, misuse of authority and supplier impact, fair process, confidentiality and purpose limitation are protected. Interviews, minutes, technical findings and management decisions are managed as separate types of records.

Insider Threats and Employee-Caused Incidents

Excess of authority, data copying, account sharing, use of personal devices or claims of intentional harm are examined within the limits of labor law, personal data and criminal law. The scope of the review is kept proportionate, and any disciplinary decision is based on verified records.

Basis: Law No. 7545 · KVKK data security

Coordination of Prosecution and Police Processes

In incidents where there is a suspicion of crime, applications, record submissions, representation, seizure or examination requests are managed together with the criminal law team. Criminal proceedings do not automatically halt regulatory notifications or internal improvement work.

Ransomware and Digital Extortion Incidents

Encryption, threats to leak data, payment demands and pressure to disclose publicly are assessed together. No payment or communication decision is made on its own without considering sanctions, proceeds of crime, insurance, payment, personal data, service continuity and record preservation aspects.

Corporate Email Compromise and Payment Fraud

In incidents involving fake instructions, account changes, impersonation of executives and unauthorized transfers, the processes of the bank, supplier, insurer, technical team and judicial authorities are planned simultaneously. The contract, authorization procedure and employee conduct are examined separately after the incident.

Unauthorized Access and Account Takeover

The affected accounts, privileged authorizations, sessions, accessed data and transactions performed are identified. Once account security is rebuilt, legal classification is made for notifications to individuals, the organization and contract parties.

Data Leaks and Publication Online

The attribution, scope and currency of records published or offered for sale are technically verified. Options for content removal, access restriction, platform notification, personal data, trade secrets and judicial process are considered together. Content removal or access restriction options are determined based on the nature of the content, the competent authority and the current application route.

DDoS and Service Availability Incidents

In denial-of-service attacks or long outages, independently of any data leak, service level commitments, customer communication, business loss, sector notifications and compensation claims are examined. The impact of the incident, its duration and the measures taken by the parties are recorded; an outage is not automatically assumed to constitute force majeure.

Basis: Law No. 7545 · 2026 duty amendments

Third-Party and Supply Chain Cyber Risk

Risks arising from a software manufacturer, maintenance company, call center, accounting service, payment provider or other supplier are mapped. Audit, incident notification, subcontractors, data access, business continuity and contract termination provisions are arranged together.

Cloud, SaaS and Data Center Security Review

The shared responsibility model, administrator access, log availability, backup, data location, sub-processors, incident notification and exit plan are examined. A provider’s standard security documentation does not remove the organization’s own obligations. The transfer basis, scope of access and sharing of records for remote access and examination from abroad are assessed separately.

Managed Security and Technical Service Agreements

The scope of SOC, monitoring, incident response, penetration testing, vulnerability scanning and digital forensics services is clearly written. Service levels, emergency calls, record ownership, confidentiality, limits of authority, report delivery and liability provisions are tested against incident scenarios.

Cybersecurity Provisions in Commercial Contracts

Minimum controls, compliance statements, incident notification period, cooperation, audits, cost sharing, liability caps and termination rights are arranged according to processing. A general sentence such as “necessary security measures will be taken” does not provide measurable allocation of responsibility.

Basis: KVKK data security · KVKK cross-border transfer · Payment services regulations

Legal Framework for Business Continuity and Disaster Recovery

The critical service, maximum tolerable downtime, alternative working method, customer commitment and regulatory thresholds are assessed together with contracts. It is ensured that the plan covers not only technical restoration but also continuity of decisions and communication.

Cybersecurity Exercise and Tabletop Scenario

Incident scenarios are prepared involving management, legal, technical team, communications and business units. During the exercise, decision time, notification content, authority gaps and supplier access are measured; the results are turned into a corrective action plan.

Training, Awareness and Management Briefing

General employee training, privileged user training and board briefings are designed with different content. Phishing, passwords, portable devices, incident reporting, confidentiality and record preservation obligations are explained by role.

Industrial Systems, OT and Connected Devices

The impact of a cyber incident on human safety and service continuity is assessed in production lines, energy facilities, medical devices or other operational technology (OT) and Internet of Things (IoT) systems. The authority, remote access, records and responsibility arrangements between the manufacturer, maintenance contractor, operator and technical team are established. Decisions on safe shutdown and return to operation rely on the assessment of the competent technical and operations teams.

Basis: Law No. 7545 · Banking regulations · Payment services regulations

Vulnerability Disclosure and Responsible Disclosure Process

A secure channel and authority flow are established for receiving, verifying, responding to and remediating a vulnerability reported by a researcher or third party. Good-faith disclosure and claims of unauthorized access are separated on the basis of concrete acts and legal limits.

Penetration Testing, Security Research and Written Authorization

The system, account, time frame, permitted methods, stop condition and third-party approval for any test are defined in writing. The protection of data accessed during testing, delivery of the report and disclosure of the vulnerability are arranged. The existence of a research or bug bounty program is not accepted as authorization to access systems outside the scope.

Basis: Law No. 7545 · KVKK data security

Cybersecurity Review in Mergers and Acquisitions

The target company’s critical assets, past incidents, vulnerabilities, suppliers, insurance, notifications and ongoing corrective actions are subjected to legal review. Pre-closing and post-closing risks are reflected in the contract, the price mechanism and the integration plan.

Cybersecurity Representations, Warranties and Indemnities

In investment and corporate transactions, the knowledge level, period and materiality threshold of cybersecurity representations are clearly written. Special provisions are prepared for known incidents, ongoing reviews, third-party impact and post-closing notification obligations.

Authorization Processes for Cybersecurity Products and Services

It is examined under current regulations whether the product, service or activity is subject to certification, documentation, approval or export license. Notification and approval requirements for share transfers, mergers, demergers and changes of control of cybersecurity companies are assessed separately. A permit or compliance date is not calculated solely from the Law’s first publication date; the relevant secondary regulation and transitional provision are checked on the date of the transaction.

Basis: Law No. 7545 · 2026 duty amendments

Cyber Insurance Policy and Claim Notice

The policy’s definition of an incident, waiting period, exclusions, approved service provider, ransom, business interruption, data breach and defense cost provisions are reviewed. At the time of an incident, notice to the insurer and the engagement of technical and legal services are carried out in line with the policy conditions.

Audit, Review and Corrective Action Plan

Internal audit, independent technical assessment or public audit findings are recorded in a common risk register. For each finding, a responsible person, deadline, acceptance criteria and closing record are determined; a technical vulnerability is not treated as closed merely by updating documents.

Post-Incident Liability, Disputes and Continuous Improvement

Options under contract breach, compensation, insurance, employee, executive, supplier and criminal liability are reviewed based on incident records. Root causes and lessons learned are linked to changes in policy, contracts, training, budget and technical controls, and a closing report is prepared.

Administrative Sanctions and Judicial Applications

Audit findings, information requests, requests for defense, administrative fines or administrative acts related to the activity are examined file by file. Authority, reasoning, proportionality, service, remedy route and time limits are verified, and a defense and, where necessary, a litigation strategy are prepared. Whether filing an application automatically suspends the act is assessed separately.

Basis: Law No. 7545 · 2026 duty amendments

Cross-Border Cyber Incident Coordination

Parallel obligations arising from systems, data subjects, group companies, customers or service providers in different countries are mapped country by country. Foreign legal opinions are obtained through an attorney authorized in the relevant country, and notifications are kept consistent with one another. In relation to the EU, NIS2, DORA and product-specific CRA obligations are examined separately in terms of activity, addressee and the relevant country. Serving EU customers does not automatically make all of these regimes apply in the same way.

Digital Products and the EU Cyber Resilience Act

For digital-element products placed on the EU market, manufacturer and other economic operator roles, exemptions, vulnerability management and product security incidents are examined under the CRA. The application of notification provisions as of September 11, 2026 and of the core obligations as of December 11, 2027 is distinguished. A notification and compliance plan is prepared with a foreign attorney and technical team after verifying the scope of the product and incident.

Basis: KVKK cross-border transfer · EU NIS2 · EU DORA · EU CRA