Turkey EU Representative

Does GDPR Apply to Turkish Companies?

Yes. Turkey’s Law on Protection of Personal Data (KVKK / Law No. 6698), enacted in 2016 and amended in 2019, is modelled on the EU’s former Data Protection Directive but has significant differences from the modern GDPR framework. Turkey has not received an EU adequacy decision, meaning EU-to-Turkey data transfers require Standard Contractual Clauses or explicit consent.

If your Turkish business exports goods to EU buyers, runs an e-commerce platform serving EU customers, manufactures products for EU brands, or processes any EU personal data — GDPR applies to you, and Article 27 requires an EU Representative.

KVKK vs GDPR — Key Differences

• No explicit extraterritorial scope: KVKK primarily applies to data controllers in Turkey; GDPR explicitly applies to non-EU entities targeting EU data subjects
• No mandatory DPO: Not required under KVKK (only mandatory for some public bodies)
• Limited breach notification: KVKK has breach notification to the Board within 72 hours, but no requirement to notify data subjects in all cases
• Different enforcement: KVKK violations carry fines of TRY 100,000-10 million (~EUR 3,000-300,000) — far lower than GDPR
• Data transfer restrictions: KVKK requires explicit consent or Board approval for cross-border transfers

Turkish Industries Most at Risk

Manufacturing & textile: Turkey is a major manufacturer for EU brands. Contact data of EU buyers, logistics data, and quality assurance records all process personal data.

Tourism: Turkish hotels, tour operators, and travel agencies serving EU tourists. Guest registrations, passport data, booking info.

E-commerce: Turkish online retailers and marketplace sellers serving EU customers.

Automotive: Turkish auto parts manufacturers and exporters with EU OEM clients.

3-Step Compliance

1. Appoint EU Shield — EU legal address
2. Update Privacy Policy — EU Representative section
3. Establish SCCs for cross-border data transfers + maintain ROPA

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