Public Announcement on the Method of Notifying the Response to Data Subjects' Applications Has Been Published

The Public Announcement on the Method of Notifying the Response to Data Subjects' Applications (the "Announcement") was published by the Turkish Personal Data Protection Authority (the "Authority") on the Authority's official website on 1 October 2026.

The Announcement sets out the following matters in summary:

• The rights of data subjects are regulated under Article 11 of the Law No. 6698 on the Protection of Personal Data (the "Law"), and pursuant to Article 13 thereof, data subjects may submit their requests regarding these rights to the data controller. The data controller is obliged to conclude the application as soon as possible, depending on the nature of the request, and within thirty days at the latest; to either accept the request or reject it by stating its grounds; and to notify the data subject of its response in writing or by electronic means.
• Article 6 of the Communiqué on the Procedures and Principles of Application to the Data Controller (the "Communiqué") likewise provides that the data controller shall take the necessary administrative and technical measures to conclude applications effectively, lawfully and in accordance with the principle of good faith, and shall notify its response in writing or by electronic means.
• In the examinations conducted within the scope of complaints submitted to the Authority, it has been determined that some data controllers responded to applications solely through telephone calls, face-to-face briefings or similar verbal methods.
• It has been emphasised that, although it is possible to contact the data subject verbally during the evaluation of the application for the purpose of requesting additional information or documents, clarifying the application, or providing information about the process, such communication shall not be deemed the response required to be given pursuant to Article 13 of the Law and Article 6 of the Communiqué.
• It has been stated that notifying the response in writing or by electronic means ensures that whether the request has been accepted, the grounds for rejection, the actions taken within the scope of the application, and the date of notification of the response are established in a clear, auditable and provable manner; and that this is of importance for data subjects to effectively exercise their rights, as well as for complaint and examination processes before the Board and potential judicial proceedings.

In this context, it has been stated that data controllers must:

• Conclude applications in accordance with the procedures and principles stipulated in the Law and the Communiqué,
• Notify the data subject of the response in writing or by electronic means,
• Take into account that verbal communication methods shall not be deemed the response required under the legislation,
• Clearly specify the extent to which requests have been fulfilled, and set out the grounds for rejected requests in a clear and comprehensible manner.

You can access the full text of the Announcement here.

Kind regards,

Zumbul Attorneys-at-Law

info@zumbul.av.tr

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