Duyurular

Turkish Competition Authority Imposes an Administrative Fine of 282 Million Turkish Lira Due to the Obstruction of an On-Site Inspection Through the Deletion of Digital Data

Turkish Competition Authority (“Authority”) has announced on 20.11.2025 the decision of the Competition Board (“Board”) concerning the data deletion incident detected during an on-site inspection conducted at an undertaking on 07.10.2025.

The public announcement can be summarized as follows:

  • Under the Act no 4054 on the Protection of Competition (“Act”), the experts of the Authority are vested with the power to examine undertakings’ books as well as all types of data and documents kept in physical or electronic media, to take copies thereof, and to request written or oral statements from employees.
  • It is stipulated that during the on-site inspection process no data deletion shall be carried out on phones, computers or similar data-containing devices used by employees after the inspection has commenced.
  • A breach of this obligation is considered within the scope of preventing and/or complicating an on-site inspection and is subjected to an administrative fine amounting to 0.5% of the undertaking’s turnover pursuant to Article 16 of the Act.
  • During the on-site inspection conducted on 07.10.2025 at the undertaking concerned, it has been determined through the forensic IT analyses carried out by the Authority’s experts that digital data were deleted by a manager after the inspection had commenced.
  • The act of data deletion has been evaluated within the scope of preventing and/or obstructing the on-site inspection and it has been decided to impose an administrative fine amounting to 0.5% of the undertaking’s gross revenues for 2024. Accordingly, an administrative sanction of 282,416,376.34 TL has been imposed on the undertaking.
  • The decision underscores the importance of transparency and cooperation during the on-site inspection process and demonstrates that undertakings must exercise utmost diligence in digital data management and inspection procedures.

You can access the full text of the public announcement here.

 

Kind regards,

Zumbul Attorneys-at-Law

info@zumbul.av.tr

 

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