NEWSLETTER-2020-metin

398 NEWSLETTER 2020 ge scale. There is no assessment regulated under the KVKK within this context. • Registry of Data Controllers: Unlike the GDPR, the KVKK imposes a registration obligation on the Data Cont- rollers Registry, namely, VERBIS, for the data controllers apart from certain exceptions. This Registry is a part of the obligation to prepare data inventory (one of the obligations under the KVKK), and forms the framework of the data inventory which the data controller is obliged to reflect its data processing activity in the most comprehensive way. The deadline to fulfill the VERBİS registration obligation of real and legal person data controllers whose annual number of employees is more than 50, or the annual financial balance sheet total is greater than TRY 25 million, or who is resident/ established abroad, is 30.06.2020. If the registration obliga- tion is not fulfilled, administrative fines from TRY 20.000 to TRY 1.000.000 may be imposed. • Recording of Processing Activities: To the contrary of the registration obligation of the KVKK upon the Data Controllers Registry, under the GDPR, it is not regulated to publicize the processing activities on a public platform. Data controllers are obliged to keep records that contain the information specified under Article 30 of GDPR, and to show these records to the Data Protection Authority when necessary. The same obligation is stipulated as the inventory preparation obligation within the KVKK and its content is regulated under the Regulation on Data Controllers Registry. • Administrative Fines: Administrative fines that are regu- lated under the GDPR are considerably higher than those regulated in the KVKK. While the upper limit of fines under the KVKK is stipulated as between TRY 20.000 and TRY 1.000.000, the upper limit under the GDPR can be determi- ned as EUR 20.000.000, or 4% of the annual turnover of the previous fiscal year.