How to Manage the Data-Subject Request Process

Data subjects have certain rights over their personal data and can apply to the data controller to exercise them. Managing these requests in an orderly and timely way is a visible part of KVKK compliance.

This content is for general information only and does not constitute legal advice.

The data subject's rights

Under KVKK Article 11, the data subject has rights such as learning whether their data is processed, requesting information, correction, erasure, learning the parties data was transferred to, and objecting to processing. A request may concern one of these rights.

Response time: within 30 days at the latest

The data controller concludes the request as soon as possible and within 30 days at the latest. If the operation incurs an additional cost, a fee from the tariff set by the Board may be charged. Missing the deadline creates both a rights violation and a complaint risk.

A healthy request process

1. Define your request channels. Written, email or via a system; how to apply should be clear.
2. Verify the applicant's identity. Giving information to the wrong person is a new breach.
3. Classify the request. Which right does it concern? Which data does it cover?
4. Track the deadline. Set up a reminder mechanism that monitors the 30-day period.
5. Record the response and its rationale. Document what you answered.

Common mistakes

• Scattered tracking. Following requests in an inbox is prone to missing the deadline.
• Skipping identity verification. Giving information to an unverified request is risky.
• Not keeping records. A record of the request and its response is the basis of accountability in an audit.

Managing the process

Tracking requests in one place, deadline reminders and response records get harder with manual methods. Kivuz KVKK is a KVKK compliance software that ensures requests are answered within the statutory deadline. Request management is part of the broader KVKK compliance process; to see the whole, request a demo.