In many companies KVKK work is done once and shelved. Yet as processes change, the inventory goes stale, retention periods expire and new transfers appear. This guide focuses on the three areas that keep compliance alive.
Why continuity matters
Türkiye's Personal Data Protection Law No. 6698 places ongoing, not one-off, obligations on data controllers: transparency notices, security measures, retention and destruction, and responding to data subject requests. All of them rest on the company's actual data flows; when the flows change, the records must change too.
The personal data processing inventory
The inventory is the backbone of compliance. For each processing activity it holds at least:
- Processing purposes and legal grounds
- Data categories and data subject groups
- Recipient groups the data is transferred to
- Maximum retention periods
- Data expected to be transferred abroad
- Technical and administrative security measures
Retention and destruction
The regulation on the erasure, destruction or anonymisation of personal data requires data to be destroyed when its retention period ends, and the destruction to be recorded. Under the regulation, periodic destruction may not be more than six months apart.
The practical difficulty is knowing which data expires when. Linking retention periods to the inventory and recording each destruction in minutes makes the obligation trackable.
Cross-border transfers
Article 9 of the Law, which governs transfers abroad, changed in 2024. Transfers can now rest on an adequacy decision, appropriate safeguards (such as standard contracts) or limited occasional cases. A standard contract must be notified to the Authority within five business days of signing.
Cloud services, software vendors and group companies often create transfers nobody noticed. Every new provider should open a transfer assessment in the inventory.
Manage it with evidence
The history of inventory changes, destruction minutes and transfer assessments are the evidence of compliance. Part of this evidence is shared with ISO 27001 work; managing both in one structure avoids producing the same document twice.
KVKK compliance is sustainable when it is run as an operation in which the inventory changes with the real data flows and every change is recorded with its evidence.
This guide is for general information and is not legal advice. Current legislation and decisions of the Personal Data Protection Board prevail.
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