The Turkish Personal Data Protection Authority (KVKK) closed 2024 with enforcement decisions and updated guidance documents that materially raise the compliance bar for companies operating in Turkey.
Key Regulatory Developments
Three areas saw the most significant activity in late 2024: cross-border data transfer mechanisms were overhauled; sector-specific guidance on health data processing was issued with stricter consent requirements; and enforcement fines escalated sharply, with several decisions exceeding TRY 5 million for systemic failures in data subject rights management.
Consent Mechanism Weaknesses
The Authority has taken a strict position on bundled consent. Companies still combining personal data consent with general terms acceptance are exposed. Consent must be granular, purpose-specific, and withdrawable with the same ease as it was given. Cookie consent implementations are under particular scrutiny.
DPIA: From Optional to Expected
Data Protection Impact Assessments are no longer optional for high-risk processing. The Authority's 2024 guidance makes clear that companies processing special categories of data or conducting large-scale profiling should conduct DPIAs as a matter of course. Cebeci Finans's KVKK compliance service covers data inventory design, consent architecture review, DPIA methodology, and ongoing regulatory monitoring.