AI System

Under the definition in the EU AI Act, an AI system is a machine-based system that generates outputs such as predictions, content, recommendations or decisions from the inputs it receives and operates with varying levels of autonomy. Chatbots, text and image generation tools, recommendation systems, credit scoring models and facial recognition systems are within this scope.

The Legal Framework in Turkey

Turkey has no AI-specific law. AI use is subject to general rules:

• KVKK: Systems trained on or processing personal data must rely on a legal basis, notice must be given, and the rules on profiling and automated decision-making must be followed.
• Cross-border transfer: Because most AI services are hosted abroad, personal data entered is subject to cross-border transfer rules.
• Intellectual property: Use of works in training data and ownership of outputs are assessed under the Law on Intellectual and Artistic Works.
• Trade secrets: Entering contracts, source code or customer information into external tools may breach confidentiality obligations.

The Personal Data Protection Authority has published recommendations on personal data protection in AI and information notes on generative AI.

Internal AI Policy

An AI policy setting out which tools may be used with which information is the first and most effective step. The policy should identify approved tools, types of information that may not be entered, human review of outputs and responsibilities. For risks of fake images and audio, see Deepfake.