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What is VERBIS?
Within the scope of Article 16 of the Personal Data Protection Law No. 6698, natural and legal person data controllers who process personal data are obliged to register with VERBIS before starting to process any personal data.
In this context, data controllers are required to register with VERBIS, an online system provided by the Turkish Personal Data Protection Agency.
Are There Any Exceptions to VERBIS Registration Obligation?
To see data controllers exempted from VERBIS registration in accordance with Article 16 of KVKK click here.
VERBIS Registration Process
Transactions and documents that must be completed before registration by data controllers who have to register with VERBIS require legal and technical knowledge.
In addition, VERBIS registration requires various commitments for the organization and if the registration does not reflect the truth, incorrect or incomplete may result in criminal consequences.
All transactions made on VERBIS are under the responsibility of the data controller.
Veri inventory must be ready before recording.
It is very important to identify categories in the data inventory.
Data Inventory & VERBIS Record
In the first stage, an internal organizational chart should be prepared and it should be specified on the basis of category (identity, communication, location, health, etc.) which personal data is processed in the departments/units within the organization. Then, a data inventory should be prepared and the following information should be included in the inventory.
▪️ Which personal data are processed in the specified categories (Identity: Name, Surname, TR Identity Number, etc.) Natural person whose data are processed (customer, employee, supplier, stakeholder, third parties)
▪️ Purpose and legal reason for data processing
▪️ What types of personal data are processed; sensitive personal data (health, race, religion) or personal data (name, contact details)
▪️ How long the processed data will be stored / Retention times
▪️ Administrative and technical measures taken regarding the processed personal data
▪️ Whether the data is transferred abroad
In the light of the data inventory prepared, it is necessary to notify the data controllers registry via VERBIS.
It should not be forgotten that; VERBIS and Personal Data Inventory should contain parallel information and should be up to date.