NEWSLETTER-2020-metin

170 NEWSLETTER 2020 Conclusion Besides the monetary fines imposed on the relevant undertakings, the topics assessed in the Decision are quite important in competition law practices. The Board made the assessment that within the sole undertaking approach, the claim of the subsidiary that a document is not under their reach or control, or it does not have access to informa- tion, does not prevent sanctions from being imposed. Also, in paral- lel with economic integrity term, the notice to the subsidiary to be delivered to the parent company was found to be in compliance with the law. Moreover, the Decision addressed the request for informa- tion and document within the scope of the data protection legislation. Hence, as it provided that the ongoing investigation is not obstructed, the Board found it reasonable for undertakings to provide data by tak- ing the necessary precautions as to concerns arising from the GDPR or other relevant national regulations.