Checklist

Employees are using AI. Nine questions your organization has to answer.

Turkey's data protection law (KVKK, Law 6698) does not mention artificial intelligence. It does not need to: a prompt containing personal data is processing, and a model running abroad is a transfer. Below is what the law asks, article by article, and what kind of mechanism it takes to be able to answer.

This page makes no compliance claim. It is not legal advice, it does not assert that any product makes an organization compliant, and it does not interpret the law on your behalf. It states what the legislation asks — with the article references and sources — and separates that from what a technical control can and cannot do. The determination is your legal team's.

01

Which employee is sending what, to which AI service?

All eight remaining questions depend on this one. An organization that cannot answer it is discussing its legal basis and its transfer regime in the abstract. Without measurement, the rest is assumption.

What it takes to answer Visibility at the network or endpoint layer. A survey or a policy document does not answer this — the person who declares their usage and the person who uses it are not the same person.
02

Is what leaves personal data, or a special category of it?

A customer name, a national ID, an IBAN, a health detail or the contents of a personnel file does not stop being personal data because it was typed into a chat box. Special categories are subject to a separate regime under KVKK art. 6.

What it takes to answer Content detection: recognizing categories of personal data inside prompts and attachments, including text inside uploaded files and images.
03

What is the legal basis for the processing?

KVKK art. 5 lists the conditions for processing: explicit consent, or one of the other enumerated grounds. For third-party data an employee pastes into a prompt on their own initiative, what that basis is remains a question the organization has to answer.

What it takes to answer This is a legal determination, not a technical one. The only thing the technical layer can supply is a record of what actually left.
04

Is a prompt a transfer abroad?

Most models in use run outside the country. KVKK art. 9 (as amended by Law 7499 art. 34, in force 01.06.2024) makes a transfer conditional on one of the art. 5/6 grounds plus an adequacy decision for the receiving country, sector or organization; where there is no adequacy decision, appropriate-safeguard mechanisms come into play.

What it takes to answer A per-provider record of what went where; and the option to route to a model running inside the organization, if the transfer is not to occur at all.
05

Does your privacy notice cover AI use?

KVKK art. 10 places a duty to inform on the data controller. Most organizations wrote their notice before transfers to AI services became routine.

What it takes to answer Not a technical mechanism — but updating the text requires the answer to question 1 first: which services are actually in use?
06

If the provider processes on your behalf, who is responsible?

KVKK art. 12(2) is explicit: where personal data is processed on the controller's behalf by another natural or legal person, they are jointly responsible for taking the required measures. The provider's own commitments do not remove your responsibility.

What it takes to answer The contractual side belongs to legal. The technical side can narrow the scope of what is transferred — data that is never sent creates no joint responsibility either.
07

Can you answer a data subject request?

KVKK art. 11 gives the data subject the right to request information about their data and to ask for its correction or deletion. "Was my data sent to an AI model?" is a question that can be asked under that right.

What it takes to answer A per-person record over a date range that can be verified from outside. No record, no answer.
08

What is the evidence for the measures you took?

KVKK art. 12(1) requires the controller to take "all necessary technical and administrative measures to provide an appropriate level of security" against unlawful processing and unlawful access. Writing a policy is an administrative measure; the technical measure has to be shown separately.

What it takes to answer The enforced rule itself, and a record that it was enforced. Being able to show the record was not altered afterwards is a separate matter.
09

Is what is sent relevant, limited and proportionate?

KVKK art. 4(2)(ç) lists proportionality among the general principles. Pasting an entire customer table to get one question answered may be connected to the purpose and still not be proportionate.

What it takes to answer Redaction: removing the fields that are not needed to answer the question, before the prompt reaches the provider.

Where a technical control stops

Four of the nine questions above cannot be answered by any product, ours included. Stating that plainly is the point of this page.

  • The legal basis (Q3) is a legal determination. Software cannot decide whether your ground is explicit consent or a legitimate interest.
  • The privacy notice (Q5) is a document your organization writes and publishes.
  • The transfer mechanism (Q4) — adequacy decision, standard contract, binding corporate rules — is a legal and procedural track run with the authority and the counterparty, not a setting in a gateway.
  • Joint responsibility (Q6) is allocated by contract and by law. A control can narrow what is transferred; it cannot reassign responsibility.

What a control can do is supply the factual input the other five questions need — what left, whose it was, where it went, what was stopped, and a record of it. That is a prerequisite for the legal work, not a substitute for it.

Where Arceris fits

Named here for transparency about who wrote this page — and bounded by the section above.

  • Questions 1, 2, 7, 8 and 9 are the ones a network-level control addresses: what is being sent, whether it contains personal data, a per-person record, enforcement of the rule, and redaction before the prompt leaves.
  • Question 4 gets a narrower answer than the legal one: an on-premise model can be routed to, so that no transfer occurs for the traffic you choose.
  • Arceris itself runs on your own infrastructure, air-gapped if required, so using it does not add a new recipient of the data.

How this differs from an AI gateway, and how it compares to named alternatives, is on the comparison page.

Sources

Article numbers and paragraph contents were checked against the official text of Law 6698 on mevzuat.gov.tr, and the article 9 amendment against the Authority's own publications, on 29 August 2026. Where the legislation is quoted, it is quoted; nothing here is paraphrased from memory.

Start with question one

The other eight depend on it. Run Arceris in your own network and measure what is actually being sent — before deciding anything.

Run a PoC in your network →