What happens if we do not appoint a representative?

You cannot complete the VERBIS registration that KVKK requires of non-resident controllers, which leaves you non-compliant and exposed to administrative fines.

How much does it cost?

Basic is USD 3,000 for the first year including onboarding, then USD 1,800 per year on renewal. Professional is USD 4,500 for the first year, then USD 3,250 per year. Minimum twelve-month term, fees excluding VAT.

How long does the appointment take?

Typically two to six weeks, depending on apostille and sworn translation timelines in your jurisdiction.

Does Kooch provide legal advice?

No. Kooch is a consultancy registered in Turkey that performs the representative function and related operational compliance work. Legal opinions, lawful basis determinations, cross-border transfer contract drafting and representation before the Authority or the courts remain the responsibility of legal counsel.

Data Controller Representative in Türkiye

Setup in Four Steps

Timing depends on document readiness, applicable certification, authentication and translation requirements, client approvals and VERBİS access. We confirm the workplan and dependencies at kickoff.

Step 1 — Appointment Resolution

We provide the agreed appointment and operational templates for review by the client and, where appropriate, separately engaged qualified Turkish counsel before execution.

Step 2 — Document Certification & Formalities

We confirm the appropriate certification, authentication and translation route for the controller’s jurisdiction and document type. Notarization, apostille, legalization and translation may be required depending on the circumstances.

Step 3 — VERBIS Registration

Kooch administers the applicable foreign-controller VERBİS registration workflow using information reviewed and approved by the controller. The controller remains responsible for the completeness, accuracy, currency and legality of the information supplied.

Step 4 — Privacy Notice Representative Details

We provide Kooch’s verified representative identity and contact details, together with a practical insertion block for the controller’s privacy notice. The controller remains responsible for the completeness and legal adequacy of its notice.

What we handle as your representative:

Authority correspondence

We receive, log and securely forward Authority correspondence and track the applicable response deadline. We relay controller-approved responses within the verified representative function. Service targets depend on the selected Basic or Professional plan.

Data subject requests (DSARs)

Applications received through the approved representative channels are logged and forwarded to the controller, with the applicable contractual forwarding target and the controller’s statutory Article 13 deadline tracked. The controller retains the substantive acceptance, refusal and response decision.

VERBIS maintenance

We administer controller-approved VERBİS changes, perform administrative consistency checks and maintain evidence of the updates. The controller determines and approves the underlying processing purposes, categories, recipients, retention information, transfers and other substantive Registry content. Relevant Registry changes are generally subject to the Regulation’s seven-day update rule.

Cross-border transfer notifications

Where Standard Contract notification support is included and separately activated, Kooch can provide authorized administrative submission support after the transfer parties have selected, completed, approved and signed the applicable official contract. Kooch does not select the transfer mechanism, act as a transfer party or sign the contract for the client.

Breach coordination

We coordinate receipt, escalation and evidence flow for incidents. The controller and, where appropriate, separately engaged qualified Turkish counsel assess notification obligations and timing. Any notification preparation or submission by Kooch requires the applicable service scope, controller decision and submission authority.

Annual review

We review the representative arrangement and controller-approved VERBİS information for changes requiring administrative follow-up. Broader processing-inventory or KVKK compliance reviews are available only where separately scoped.

What the Representative Does Not Do

Kooch is not a law firm. We are a Türkiye-registered consultancy that performs the representative function and the operational compliance work around it. Formal legal matters remain with the client and, where appropriate, separately engaged qualified Turkish counsel.

Legal opinions on whether KVKK applies to a specific processing activity
Drafting or negotiating Standard Contracts, Binding Corporate Rules, or undertaking letters
Representation before Turkish administrative courts
Determinations of lawful basis under KVKK Article 5 or 6
Health, genetic, biometric, clinical-trial and other sensitive-sector legal matters are subject to enhanced acceptance review and, where appropriate, separate qualified Turkish-counsel involvement.
Tax, employment, or commercial law matters

Representative Service Options

One annual fee and two service levels for the representative function. Onboarding includes the Appointment Resolution template, document-formality coordination where required, initial VERBİS registration, a representative identity/contact insertion block, and a kick-off call with documented escalation and continuity contacts. Minimum 12-month term. All fees are in USD, excluding VAT (KDV).

Onboarding (one-time, included in Year 1)
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Appointment Resolution template

Document-formality coordination, where required
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Initial VERBIS registration
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Representative identity/contact insertion block
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Kick-off call and documented escalation/continuity contacts

Ongoing representation
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Listed in VERBIS as your Türkiye representative
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Authority correspondence acknowledgment target
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Included DSAR volume (forwarding target: 1 business day)
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VERBIS record maintenance
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Standard Contract administrative notification support

Breach coordination time included
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Annual representative-function review
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Quarterly representative-function review
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Quarterly KVKK Authority guidance briefing
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Terms & Fees
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Minimum term
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Year 1 fee (includes onboarding)
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Annual Representative Service Fee
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Basic

Core representative coverage for straightforward, lower-volume processing.

Onboarding (one-time, included in Year 1)

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Appointment Resolution template

Apostille &Document-formality coordination, where required

Initial VERBİS registration

Representative identity/contact insertion block

Kick-off call and documented escalation/continuity contacts

Ongoing representation

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Listed in VERBİS as your Türkiye representative

Authority correspondence acknowledgment target

24 business hours
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Included DSAR volume (forwarding target: 1 business day)

20 / year
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VERBİS record maintenance

Standard Contract administrative notification support — subject to activation, authority and completed transfer documentation

Breach coordination time included

First 4 hours / year
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Annual representative-function review

Quarterly representative-function review

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Quarterly KVKK Authority guidance briefing

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Terms & Fees

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Minimum term

12 months
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Year 1 fee

USD 3,000
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Annual Representative Service Fee

USD 1,800
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Request a proposal

Professional

Priority response, higher included volumes and quarterly operational reviews for organizations that need enhanced service coverage. All engagements remain subject to Kooch’s client-acceptance and service-scope review.

Onboarding (one-time, included in Year 1)

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Appointment Resolution template

Apostille &Document-formality coordination, where required

Initial VERBİS registration

Representative identity/contact insertion block

Kick-off call and documented escalation/continuity contacts

Ongoing representation

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Listed in VERBİS as your Türkiye representative

Authority correspondence acknowledgment target

8 business-hour (priority)
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Included DSAR volume (forwarding target: 1 business day)

35 / year
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VERBİS record maintenance

Standard Contract administrative notification support — subject to activation, authority and completed transfer documentation

Breach coordination time included

First 8 hours / year
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Annual representative-function review

Quarterly representative-function review

Quarterly KVKK Authority guidance briefing

Terms & Fees

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Minimum term

12 months
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Year 1 fee

USD 4,500
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Annual Representative Service Fee

USD 3,250
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Request a proposal

Service availability is subject to Kooch’s client-acceptance, scope, capacity and operational-readiness review. Sensitive-sector, active-investigation, breach, disputed-scope and other elevated-risk engagements may require additional review or may fall outside the standard service.

Frequently Asked Questions

Q1. Who is legally required to appoint a data controller representative in Türkiye?

A controller established outside Türkiye that, after the applicable KVKK and VERBİS assessment, is required to register must use a Türkiye-based veri sorumlusu temsilcisi for the foreign-controller registration route.

Q2. What happens if we don't appoint one?

If a foreign controller is required to register with VERBİS, the applicable foreign-controller registration route requires a Türkiye-based representative. Failure to comply with an applicable Registry obligation may expose the controller to administrative enforcement under KVKK Article 18.

Q3. What kind of inquiries will you handle?

Applications received through approved representative channels and Authority correspondence are logged and securely forwarded under the applicable contractual service targets. Kooch tracks the controller’s relevant deadline and relays controller-approved responses within the representative function. The controller remains responsible for substantive decisions and responses.

Q4. Is a data controller representative the same as a Data Protection Officer (DPO)?

No. A veri sorumlusu temsilcisi is the Türkiye-based representative used in the foreign-controller VERBİS framework where the appointment requirement applies. An irtibat kişisi is a separate VERBİS communication role, and neither role is equivalent to a GDPR DPO.

Q5. Do you provide legal advice?

Kooch provides the verified representative and operational compliance functions described on this page. Formal Turkish-law opinions, contentious regulatory defence, objections, appeals, litigation and other lawyer-reserved work are handled through separately engaged qualified counsel where required.

Data Controller Representative in Türkiye for Foreign Controllers

Your Türkiye-Based Data Controller Representative

When a Türkiye-Based Representative Is Required

How the Representative Relationship Works

Setup in Four Steps

What we handle as your representative:

What the Representative Does Not Do

Representative Service Options

Frequently Asked Questions

Main pages

Solutions