Data Protection & Cybersecurity

EXPERTISE | Services

Data Protection & Cybersecurity

For multinational businesses, data protection work in Turkey often centres on the way personal data moves through the organisation: how it is collected and used locally, shared with service providers, transferred within the group and sent outside Turkey. We advise on those arrangements as well as the policies, contracts and regulatory processes that support them.

International data transfers are a key part of the practice. We advise on the mechanisms available under Turkish law, including standard contracts and binding corporate rules, and assist with the related filings and regulatory requirements. We also act in investigations and proceedings before the Turkish Personal Data Protection Authority and Personal Data Protection Board.

Our cybersecurity work covers regulatory compliance as well as incident response. We advise on Turkish cybersecurity legislation and regulatory requirements, contractual and governance issues and the legal response to security incidents. We also assist with privacy and data-governance issues arising from artificial intelligence and other new technologies.

Turkish data protection compliance programmes and implementation in Turkey of group privacy frameworks developed under GDPR or other international standards
Data mapping, gap analyses and registration with the Data Controllers’ Registry Information System (VERBİS)
Privacy notices, consent documentation, internal privacy policies and data-retention frameworks
Data processing, data sharing, controller-processor, vendor and other data-related agreements
International data transfers, including standard contracts, binding corporate rules and other transfer mechanisms available under Turkish law
Data-subject rights, direct marketing, cookies, online tracking and employment-related privacy matters
Data protection aspects of M&A transactions, corporate reorganisations and new products or projects
Investigations, complaints and enforcement proceedings before the Personal Data Protection Authority and Board
Cybersecurity governance, internal policies, third-party contractual requirements and Turkish cybersecurity regulatory compliance
Legal support in cybersecurity and personal data incidents, including notification assessments and coordination with technical and other advisers
Privacy and data-governance issues arising from AI, automated decision-making and the use of AI tools within businesses

Advised a global streaming service on the data protection workstream for its Turkish launch, including mapping cross-border data flows, determining the applicable Turkish standard contract structures, preparing and filing the standard contracts with the Personal Data Protection Authority and updating its record of processing activities and VERBİS registration.
Advised a Turkish subscription video-on-demand platform on the legal response to cybersecurity vulnerabilities and compromised user accounts, including the information provided to the regulator.
Advised a Turkish online travel and ticketing platform on a comprehensive data protection compliance programme, including data inventories, contractual documentation, regulatory filings and internal awareness training.
Advised a multinational business on a personal data breach caused by a cyber attack on a third-party provider holding its data, including the factual and legal investigation of the incident, assessment of the notification obligations, the resulting breach notifications and preparation of the incident report.