AI Automation and KVKK: a Data-Flow Checklist
Decision summary: Map AI data flows, provider access, retention and overseas transfers before launch. A practical checklist for technical and legal review.
Separate the legal questions
Under Türkiye’s Law No. 6698, Article 4 sets general principles, Articles 5–6 address processing conditions, and Articles 8–9 address transfers. These are different checks. Do not copy GDPR article numbers or assume that a GDPR assessment proves KVKK compliance. This guide helps prepare an implementation review; it is not a legal opinion.
For one real workflow, list the purpose, data categories, people affected, controller, providers and access roles. Have the applicable conditions and notices reviewed for that actual use before sending personal data to a model.
Draw the complete data path
Include the form, automation service, model, logs, backups, support access and subcontractors. Record where each copy can be accessed, whether it is used for training and how access ends. A hosting region or a paid enterprise plan alone does not settle these questions.
For an order-status assistant, test whether a status code is sufficient instead of a full customer email. Removing a name does not necessarily anonymise a record if other fields can identify the person. Use synthetic or properly anonymised examples for development where feasible.
Review transfers and retention separately
The amended Article 9 contains several routes and conditions for overseas transfers; standard contracts are one safeguard, not a blanket permission. Ask a qualified adviser to assess the actual parties, onward access, applicable route and procedural duties using the Authority’s current guidance.
Set retention by data category, purpose and applicable obligations. There is no universal 30–90-day rule for all AI logs. Specify what deletion, destruction or anonymisation means for each copy, who executes it and how completion is evidenced. Include backups and legal holds in that review.
Turn the review into release checks
Test an access denial, a deletion request, a provider failure and a change of provider settings. Keep test records without unnecessarily copying personal content. Name an owner for incidents and a route for requests from affected people. Set review frequency according to risk and change, not an invented statutory interval.
Give the team an approved-tool policy and a usable alternative to personal AI accounts. Before launch, resolve unknown recipients and purposes, confirm the agreed technical controls, and document outstanding legal decisions. Encryption, a contract or human approval alone does not certify compliance.
Methodology
Claims are assessed for feasibility, cost, risk and measurability. Illustrative calculations are assumptions; legal, security and investment decisions require primary-source verification.
Source note
In-text links and named regulatory or technical documents are starting points. Unverified customer outcomes are not published.
- KVKK — Personal Data Protection Law (current Articles 4–9)
- KVKK — Yurt Dışına Aktarım
- KVKK — Silme, Yok Etme ve Anonim Hale Getirme Yönetmeliği
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Frequently asked questions
Does a model API automatically comply with KVKK?
No. Assess the actual data, purpose, parties, access, retention and transfer arrangement; a product label is not a legal finding.
Must every log be deleted after 30 days?
No universal period applies here. Define and justify periods per category and obligation, then test the agreed deletion or anonymisation process.
Is hosting in Türkiye sufficient?
It does not by itself resolve processing conditions or access from abroad. Include support, subcontractors and backups in the data-flow review.