VERBIS Registration Obligation for the Non-Resident Data Controllers
In the event that some or all of the personal data is transferred from Turkey to the founder / partner foreign company located abroad and the foreign company uses this data for its own purposes, there is an obligation to register with the Data Responsible Register Information System (“VERBIS”) for non-resident foreign companies. The Turkish DPA's Board decision numbered 2019/387 to postpone the deadline for VERBIS registration until 30 June 2020 for (i) natural or legal person data controllers whose number of employees exceeds 50 or whose annual balance sheet total (total assets on the balance sheet) exceeds TRY 25 million and (ii) natural or legal person data controllers that are resident outside of Turkey.
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