KVKK and GDPR Compliance Operations Outsourcing

Last updated: November 11, 2026

Data protection compliance operations outsourcing gives you a team that runs the day-to-day work of privacy compliance: keeping the data inventory current, handling data subject requests, maintaining notices and consent records, running retention and deletion cycles, supporting breach response and preparing evidence for audits. It is designed for companies that process personal data in Turkey under KVKK (Law No. 6698), and for international companies that also need GDPR operations. We are an operations team, not a law firm: legal interpretations and final decisions stay with your DPO or legal counsel, while we make sure the agreed processes actually run.

KVKK and Data Protection Compliance Operations Outsourcing

Who needs it

International companies with a subsidiary, branch, customers or employees in Turkey that fall under KVKK
Turkish companies that sell to the EU or UK and must also meet GDPR or UK GDPR requirements
E-commerce, retail, healthcare, education, HR and fintech businesses handling large volumes of personal or special category data
Companies that completed a one-off compliance project with a law firm, but whose inventory, notices and deletion schedules are no longer kept up to date
DPOs and legal teams who need operational capacity rather than more legal opinions

The common problem is that compliance documents are written once and then left alone, while systems, vendors and processes keep changing. When a data subject request, a breach or an audit arrives, nobody can quickly show what data is held, where, why and for how long.

Regulatory topics that affect operations

VERBIS registration and data inventory

Under Article 16 of KVKK, many data controllers must register in VERBIS, the Data Controllers Registry Information System. Data controllers resident outside Turkey are within scope, and domestic thresholds are set by Board decisions that change over time, so we confirm your obligation against the current decision. The VERBIS entry is derived from your data inventory (categories, purposes, recipients, transfers abroad, retention periods) and needs updating when the inventory changes. For GDPR, the same inventory supports your Article 30 records of processing activities.

Privacy notices and explicit consent

KVKK Article 10 and the related communiqué require data subjects to be informed at the time of collection; explicit consent is needed only where no other legal basis applies, and must not be bundled with the notice. We review notices and consent texts across websites, apps, forms and HR processes, and keep consent records auditable.

Data subject requests

Requests under KVKK Article 11 must be answered within 30 days, and GDPR requests generally within one month. We operate an intake channel, verify identity, coordinate data searches with system owners, draft responses for your approval and keep a request log.

Cross-border transfers

Since the 2024 amendment of KVKK Article 9, transfers abroad can rely on adequacy decisions, appropriate safeguards such as standard contracts approved by the Board, or limited exceptions. Standard contracts must be notified to the Board within five business days of signature. For GDPR transfers, SCCs (and for the UK the IDTA or Addendum) with transfer impact assessments apply. We track contracts, deadlines and notifications.

Retention, deletion and anonymisation

The Turkish regulation on deletion, destruction and anonymisation requires a retention and destruction policy and periodic destruction at intervals of no more than six months for controllers that must have such a policy. We run these cycles with system owners and keep the records that prove deletion took place.

Data breach notification

The Board expects breaches to be notified within 72 hours of becoming aware of them, with data subjects informed as soon as reasonably possible; GDPR also uses a 72-hour window for supervisory authority notification. We maintain the breach register, prepare notification drafts and coordinate with your security team or SOC.

Service scope

Area	Typical tasks
Data inventory and RoPA	Interviews with departments, inventory updates, VERBIS and Article 30 record maintenance
Notices and consent	Review of privacy notices, cookie banners, consent texts and records
Data subject requests	Intake, identity verification, data search coordination, response drafts, request log
Vendor and transfer management	Processor list, DPA tracking, transfer mechanism and notification deadlines
Retention and deletion	Retention schedule, periodic destruction cycles, deletion evidence
Breach support	Breach register, notification drafts, timeline and lessons learned
Training and awareness	Short role-based training, phishing and privacy awareness campaigns
Audit evidence	Policy library, control evidence, monthly compliance dashboard

Working models

Model	How it works	Best for
Managed compliance operations	We run the agreed processes end to end and report to your DPO or legal team	Companies without a privacy team
DPO support	Analysts support your DPO with inventory, requests and evidence	Busy DPOs and legal teams
Dedicated privacy analyst	A named analyst works inside your organisation and tools	Large or high-volume environments
Project plus run	Initial gap clean-up followed by ongoing operations	Companies with outdated documentation

Remote, on-site or hybrid arrangements are possible, and the team can range from a single analyst to a larger group.

Process and typical timelines

Weeks 1–2: document review, stakeholder map, current inventory and open requests.
Weeks 3–6: inventory update, gap list and prioritised action plan agreed with your counsel.
From month 2: routine operations: requests, vendor tracking, deletion cycles and monthly reporting.
Quarterly: inventory refresh, policy review and training.

The team typically starts within 1–2 weeks of agreement.

SLA and KPI table

KPI	What it measures
Request response time	Days from receipt to response, against legal deadlines
Request backlog	Open requests by age
Inventory freshness	Share of processes reviewed in the last cycle
DPA coverage	Share of processors with a signed DPA
Deletion cycle completion	Destruction cycles completed on schedule with evidence
Training completion	Share of staff completing assigned training

Pricing factors

Factor	Effect on cost
Organisation size and number of processes	Drives inventory and review effort
Request volume	Number of data subject requests per month
Jurisdictions	KVKK only, or KVKK plus GDPR/UK GDPR and others
Number of vendors and transfers	Affects contract and notification tracking
Language needs	Turkish, English or other languages
Dedicated or shared analyst	Level of availability and specialisation

In-house, freelancer or outsourcing

Criterion	In-house	Freelancer	Outsourcing
Continuity	Depends on one person	Irregular	Process-based with replacement process
Time to start	Hiring takes months	Fast but limited	Typically 1–2 weeks
Coverage of KVKK and GDPR	Depends on skills	Varies	Team with both perspectives

KVKK and Data Protection Compliance Operations Outsourcing — overview

Risks and mitigations

Confusing operations with legal advice: clear split of roles; your counsel approves interpretations.
Access to personal data: minimum necessary access, logged and reviewed.
Missed deadlines: request and transfer trackers with automatic reminders.
Outdated documents: scheduled reviews tied to system and vendor changes.

Security, confidentiality, NDA and intellectual property

Contract framework: we work under a B2B service agreement with a clear statement of work. An NDA is signed before any access is granted, and all deliverables, inventories, templates, policies, registers and reports created for you are assigned to you as intellectual property. Where we process personal data on your behalf, we sign a GDPR-compliant data processing agreement (DPA) with Standard Contractual Clauses (for UK clients, the IDTA or UK Addendum); on the Turkish side the team also complies with KVKK (Law No. 6698). Team members are employed by 360 Soft under Turkish labour law, so there is no employment relationship between them and your company.

Local data protection rules in your own country also apply, and we align processes with your DPO’s requirements for each jurisdiction.

Illustrative scenario

Illustrative scenario: a European software company opens a sales office in Istanbul and begins processing data of Turkish customers and employees. The team confirms the VERBIS obligation with the company’s counsel, builds the inventory, prepares Turkish privacy notices, tracks the standard contract notification for transfers to the EU parent and sets up a request log. This example is for illustration only.

Selection checklist

Do they understand both KVKK and GDPR operations?
Is the split between operations and legal advice clear?
Do they keep auditable logs for requests, consents and deletions?
Can they work in your tools and languages?
How is their access to personal data limited and logged?
Is there a replacement process?
Are NDA, DPA and IP assignment in the contract?

Frequently asked questions

Are you a law firm?

No. We run compliance operations. Legal interpretations and final decisions remain with your DPO or legal counsel, with whom we work closely.

Does KVKK apply to foreign companies?

KVKK can apply to companies outside Turkey that process personal data of people in Turkey, and data controllers resident abroad are within the scope of VERBIS registration. Your counsel should confirm your specific situation.

Can you handle both KVKK and GDPR?

Yes. The same inventory and processes can support KVKK, GDPR and UK GDPR, with jurisdiction-specific notices, deadlines and transfer mechanisms.

How fast must data subject requests be answered?

Under KVKK within 30 days, and under GDPR generally within one month, extendable in limited cases.

Do you handle VERBIS registration?

We prepare and maintain the information derived from your inventory and support the registration and updates on your behalf as authorised.

What about transfers of data abroad?

We track the transfer mechanism for each flow, including standard contracts and the five-business-day notification to the Board under KVKK, and SCCs for GDPR.

Do you support data breach response?

Yes. We maintain the breach register, draft notifications and coordinate timelines with your security team and counsel.

Do you need access to our personal data?

Only the minimum needed for the agreed tasks, under a DPA, with access logged and reviewed.

How quickly can you start?

Typically within 1–2 weeks of agreement.

Who owns the documents you create?

You do. All inventories, templates, policies and reports are assigned to you under the contract.

Talk to us

Tell us about your KVKK and data protection compliance needs and we will come back with a scoped proposal, a team plan and a realistic start date (typically 1–2 weeks). Call +90 850 335 10 87, message us on WhatsApp, email info@360-soft.com or use the contact page. 360 Soft Marketing Yazılım ve Danışmanlık Ltd. Şti., Nidakule Ataşehir Batı, Barbaros Mah. Begonya Sk. No:1 D:2, 34746 Ataşehir/İstanbul.

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KVKK and Data Protection Compliance Operations Outsourcing