Registration with the Data Controllers’ Registry cannot be separated from the processing inventory. Scope, exemptions and the duty to keep entries current.
Under Turkish data protection law, data controllers may be required to register with the Data Controllers’ Registry (VERBİS) according to criteria set by the Board. The scope of the obligation varies by headcount, annual balance sheet total and the nature of the data processed.
Registration cannot be handled independently of the processing inventory. The data categories, recipient groups and retention periods notified to the registry must be consistent with the inventory.
Registration is not a one-off step: entries must be updated whenever the notified information changes. The most common shortcoming in practice is a failure to update the registry when a new processing activity begins.
This note is for general information; current Board decisions and announcements should be followed for scope and exemptions.
This content is for general information only and does not constitute legal advice.
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