Turkish Personal Data Protection Authority Publishes Public Announcement on VERBİS Notifications for Personal Data Processed within Joint Ventures, Consortia and Ordinary Partnerships

Turkish Personal Data Protection Authority (“Authority”) has published, on its official website on 16 March 2026, a public announcement (“Public Announcement”) regarding the notification to VERBİS of personal data processed in the course of activities carried out within structures such as joint ventures, consortia and ordinary partnerships.

The Public Announcement highlights, in summary, the following points:

• The deadline for real and legal person data controllers processing personal data to fulfil their registration and notification obligations to VERBİS pursuant to Law No. 6698 on the Protection of Personal Data, Article 16, was set as 31 December 2021. Data controllers that become subject to this obligation after this date are required to complete their VERBİS registration and notification within thirty days following the date on which the obligation arises.
• It has been observed that certain requests for opinions submitted to the Authority revealed uncertainties regarding the VERBİS registration obligation of joint ventures, consortia and ordinary partnerships. The Authority further identified, through its examinations, that some of these structures had submitted applications for registration to VERBİS in their own name. In this respect, it was considered necessary to recall the principles set forth in the decision of the Personal Data Protection Board dated 9 June 2021 and numbered 2021/569.
• The Authority emphasized that structures such as joint ventures, consortia and ordinary partnerships do not possess a separate legal personality independent from the parties forming the partnership. Accordingly, such structures should not create a separate VERBİS registration in their own name.
• In this context, it is first necessary to determine whether the parties forming the partnership are subject to the obligation to register with VERBİS. Subsequently, partners that are under the obligation to register must, when making their VERBİS notifications, include not only the personal data processed within the scope of their own activities but also the personal data processed within the activities carried out under the joint venture, consortium or ordinary partnership.

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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