Turkish Data Protection Institution has announced a decision relating to the branches or liaison offices of the foreign companies, either they are obligated to be involved to Data Controllers Registry or not.
1. Data controllers located in a foreign country shall be signed up to the Registry in case they are processing data directly or through their branches in Turkey,
2. The branches located in Turkey shall be acknowledge as a “Data Controller” separate from the main company. The obligation to sign up for Data Controllers Registry shall be evaluated after checking the requirements such as the number of employees and annual gross revenues of the branch.
3. In order to set up a Liaison Office in Turkey main rule is the Central Company shall be incorporated under foreign country regulations and the Liaison Office shall not commence any business activities in Turkey. Liaison Office could be established only for the purposes of communication, conducting feasibility research, conducting some studies in social and cultural fields, preparing for mergers and acquisitions between companies, publicity and advertising, keeping abreast of job opportunities in the country and informing the central company about these issues. Because Liaison Offices are not conducting any commercial activity and therefore are not functioning as branches, they are not obligated to sign up to the Data Controllers Registry.
Please find the full text of the Data Protection Institution’s Decision in Turkish; https://kvkk.gov.tr/Icerik/5545/2019-225
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