Article 27 UK GDPR · Turkey

UK representative for Turkish companies

Turkish exporters know data protection through KVKK and VERBIS, and that familiarity works against them here. Having registered domestically feels like having done the paperwork. The United Kingdom asks for something entirely different: not a registration, but a named representative established in Britain who can be written to.

KVKK registration and Article 27 are not the same instrument

VERBIS registration is a filing with the Turkish authority. Article 27 of the UK GDPR is a private mandate: a written designation naming an entity in Britain, published in your privacy notice and shown on request. One is a database entry at home, the other is a contact point abroad, and no amount of the first produces the second.

The British market Turkish exporters supply in volume — Most Turkish companies meet this rule inside a buyer questionnaire.

A British authority looking for the representative named in a supplier file — A registration at home is not a designation abroad.

Exporters, and the buyers who now ask

Textiles, furniture, food and automotive parts move from Turkey to Britain in volume, and much of that trade is business to business. The personal data involved is unglamorous — buyer contacts, logistics staff, warranty registrations — and it is still personal data about people in the United Kingdom. British buyers have begun asking for the representative in their supplier questionnaires, which is how most Turkish companies first meet the requirement.

Direct-to-consumer changes the volume, not the rule

Turkish brands selling directly to British consumers through their own sites or through platforms hold order histories, addresses and payment identifiers. The obligation is identical to the B2B case; what changes is how many people can make a request, and therefore how quickly the absence of a contact point is noticed.

Transfers need their own mechanism

The United Kingdom has not made an adequacy finding for Turkey. Personal data moving from Britain generally requires the IDTA or the addendum. Companies that handle the designation and the transfer paperwork together avoid the common sequence where the contract is signed, the representative field is left open, and both are reopened later.

Ne yayınlamanız gerekiyor

One paragraph in your privacy notice, naming an entity established in the United Kingdom with an address a British reader can write to. We supply it in Turkish and in English, with REP27 LTD, company number 17385889 and the Suffolk address. Your KVKK text stays as it is: it answers a different authority.

What KVKK does and does not do

VERBIS registration	Turkey	A filing, not a designation
KVKK obligations	Turkey	Enforced by the KVKK authority
UK GDPR Article 27	United Kingdom	Representative established in Britain
Transfers UK → Turkey	No adequacy finding	IDTA or addendum required
What a UK buyer asks for	The named representative	With a verifiable code

The supplier questionnaire that started it

Most Turkish companies arrive here holding a British buyer's questionnaire with one field they cannot complete. The rest of the form is straightforward — quality, logistics, insurance — and this one asks for something that does not exist yet. It is a small item on a long list, and it is the item that holds the contract, because the buyer's own compliance team cannot sign around it.

Questions from Turkish companies

We are registered with VERBIS. Is that enough?

No. VERBIS is a Turkish registration. Article 27 requires a designation naming an entity established in the United Kingdom.

We only sell to British businesses, not consumers.

Business contacts are individuals. Their names, work emails and phone numbers are personal data under the UK GDPR.

Is Turkey covered by a UK adequacy decision?

No. Transfers from the UK generally require the IDTA or the addendum to the standard contractual clauses.

What does a British buyer actually check?

That a representative established in Britain is named, and that the appointment resolves on a public register.

Appointed today, verifiable today

One annual fee, no charge per request. From €290 a year for the United Kingdom, €390 for the United Kingdom and the Union together.

How the UK service works Pricing

The named contact point a Turkish exporter publishes for British buyers — A VERBIS entry is a filing at home. This is an address abroad.

Compliance review of a supplier questionnaire with one field left open — The rest of the form is quality and logistics. This is the field that holds it.

Companies elsewhere, same obligation

What changes from one country to the next is not the rule but the route into it.