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VERBIS Registration Obligation Has Been Introduced for Associations, Foundations, and Unions with Economic Enterprises

Personal Data Protection Board (“Board”); Data Controllers Registry Information System (“VERBIS”), dated 22/04/2020 and 2020/ with its resolutions dated 02/04/2018 and numbered 2018/32 as amended with the number 315, brought an exception to the obligation to register with VERBIS for associations, foundations, and trade unions residing in Turkey that process personal data following the relevant legislation and purposes, limited to their fields of activity.

Upon this exception decision made by the Board, as a result of the evaluations made to eliminate the hesitations about whether foundations, associations, and unions with economic enterprises are within this exception; It has decided that this exemption will not be valid for the economic enterprises of associations, foundations, and unions "due to their commercial activities to generate income".

As a result of this evaluation, the Board, with its decision dated 09/06/2021 and numbered 2020/315, changed the aforementioned decision and decided to apply this exception only to "foundations, associations, and unions that do not have an economic enterprise affiliated with it". The necessity of registering with VERBIS has emerged for those who have an economic enterprise affiliated to them from resident associations, foundations, and unions.

According to this decision made by the Board on 09/06/2021 and published in the official gazette on 24/06/2021, associations, foundations, and unions that have economic enterprises affiliated to them must register with VERBIS by only entering information about the activities of economic enterprises during their registration.

Before we forget, we need to evaluate this decision of the Board together with the Board's Decision No. 2018/88 published in the Official Gazette dated 18.08.2018. Namely; there is no obligation to register VERBIS for institutions other than data controllers with more than 50 employees per year or with an annual financial balance of more than 25 million TL, all data controllers residing abroad, data controllers whose main field of activity is processing special personal data, and data controllers of public institutions and organizations. In this respect, associations, foundations, and unions are not obliged to register with VERBIS if the number of employees in economic enterprises is more than 50, the annual financial balance sheet total is more than 25 million TL, or if the main activity of the economic enterprise is not processing specialty personal data.

During the meeting with the Board, it was stated that the VERBIS registration period of the economic enterprises that meet the requirements for VERBIS registration is until 31.12.2021.

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