Technical Measures
Also known as: Technical Security Measures, Information Security Controls, KVKK Article 12, Teknik Tedbirler
Author Ali Gül
In short
Measures taken by the controller in information systems to secure personal data, such as access management, logging, encryption, firewalls, backups and penetration testing.
Article 12 of the KVKK requires controllers to take all necessary technical and organisational measures to ensure an appropriate level of security to prevent unlawful processing of and access to personal data and to safeguard it. Technical measures are the information systems side of this obligation.
Main Technical Measures
The Board’s Personal Data Security Guide (Technical and Organisational Measures) highlights:
- Authorisation matrix and access management: Each employee accessing only the data needed for their role,
- Logging: Keeping and regularly reviewing access and activity logs,
- Encryption and authentication: Encrypting data and multi-factor authentication,
- Network security: Firewalls, malware protection and patch management,
- Backups: Regular backups and backup security,
- Testing: Penetration testing and vulnerability scanning,
- Portable media: Security measures for portable storage and remote access,
- Data masking: Pseudonymisation and masking in test and analytics environments.
Special Category Data
The adequate measures set by the Board for special categories of personal data must also be taken, chiefly storing such data using cryptographic methods, using secure transfer channels and logging access.
A Risk-Based Approach
The level of measures depends on the nature and volume of data processed, the processing environments and the harm a breach would cause data subjects. In a personal data breach, the Board’s first question is whether the necessary measures were taken. Breach of the data security obligation is subject to one of the highest administrative fines under the KVKK. The Cybersecurity Law that entered into force in 2025 also imposes additional obligations on institutions in critical sectors; see Cyber Incident.
Frequently Asked Questions
Who decides which technical measures we must take?
The KVKK requires an appropriate level of security without a definitive list. The Board's Personal Data Security Guide and the adequate measures set for special category data are the main benchmarks; company size, the nature of data processed and risks are also considered.
If we use a cloud service, is the provider responsible for technical measures?
No. The cloud provider is a data processor and the controller is jointly liable with it for taking measures. The provider's security measures should be secured by contract.
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- Rights Over a Person’s Image and Photograph 15.10.2024
- Can the Corporate E-mail Histories of Employees Who Leave Their Jobs Be Made Available to Another Employee? – An Evaluation in the Context of the Law on the Protection of Personal Data 06.05.2024
- Deepfake Technology – Legal Challenges and Key Questions 17.11.2023
- Push Notifications in Turkish Law: Legal Obligations and User Rights 25.10.2023
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