09 February 2022
Relationship Between ISO 27001 & KVKK
Providing security of your information assets is part of Turkish Personal Data Protection Law (KVKK) and by creating an information security system for your business, having an ISO 27001 certification is the best way to document the measures taken by your organization in this context.
The purpose of ISO 27001 standard is to lay down conditions for establishing, implementing, maintaining, and continually improving an information security management system.
Information Security Management System maintains the confidentiality, integrity, and accessibility of information by applying the risk management process and provide assurance to related parties / parties interested that risks are managed properly.
The international ISO 27001 standard which consists of general requirements and Annex A controls, explains the details required for organizations to ensure information security.
Are Organizations with ISO 27001 Certificate Compliant with KVKK?
The first paragraph of Article 12 of KVKK that came into force in April 7th, 2016, sets forth the following provisions:
"The data controller is obliged to
a) prevent unlawful processing of personal data,
b) prevent unlawful access to personal data,
c) take all necessary technical and organizational measures to provide an appropriate level of security."
The measures to be taken within this scope are elaborated in the Personal Data Security Guide (Technical and Administrative and Organizational Measures) published by Turkish Data Protection Authority.
The fact that the general principle of both ISO 27001 and KVKK is to ensure confidentiality and security, surely enables Organizations with ISO 27001 certification to adapt to KVKK faster and smoothly.
However, it would be a great mistake for the organizations to think that they have become fully compliant with KVKK by taking only the measures within the scope of the standards due to existence of important points that distinguish KVKK and ISO 27001 from each other.
What are the similar aspects between the technical measures to be taken within the scope of the Law on the Protection of Personal Data and the control items included in the ISO 27001 standard?
| Summary of Technical Measures to be Taken within the Scope of Personal Data Security Guide (Technical and Organizational Measures) | ISO/IEC 27001:2013 Standard Clause |
|---|---|
| Authorization Matrix Authorization Control | A.9.2 User Access Management |
| Access Logs | A.12.4.1 Event logging |
| User Account Management | A.9.4.2 Secure log-on procedures |
| Network Security | A.13.1.2 Security of network services |
| Application Security | A.14.2.6 Secure development environment |
| Encryption | A.10.1 Cryptographic controls |
| Penetration Test Intrusion Detection and Prevention Systems | A.12.6.1 Technical Vulnerability Management |
| Log Records | A.12.4.1 Event logging |
| Data Masking | N/A |
| Data Loss Prevention Software | A.12.6.1 Technical vulnerability management |
| Backup | A.12.3.1 Information backup |
| Firewalls | A.14.1.2 Securing application services on public networks |
| Up-to-date Anti-Virus Systems | A.12.2.1 Controls against malware |
| Deletion, Destruction, or Anonymization | A.8.3.2 Destruction of Media |
| Key Management | A.10.1.2 Key Management |
What are the similar aspects between the administrative measures to be taken within the scope of the Law on the Protection of Personal Data and the control items included in the ISO 27001 standard?
| Summary of Organizational Measures to be Taken within the Scope of Personal Data Security Guide (Technical and Organizational Measures) | ISO/IEC 27001:2013 Standard Clause |
|---|---|
| Preparing Personal Data Inventory | A.8.1.1 Inventory of Assets |
| Corporate Policy (Access, Information Security, Usage, Retention and Destruction vb.) | 5.2 Policy |
| Agreements (Data Controller – Data Controller & Data Controller – Data Processor) | A.7.1.2 Terms and Conditions of Employment |
| Non-disclosure Agreements | A.15.1.2 Addressing Security Within Supplier Agreements |
| Internal Periodic and Random Audit | 9.2 Internal Audit |
| Risk Analysis | 6.1.2 Information security risk assessment |
| Employment Contract, Disciplinary Regulation (Addition of Appropriate Provisions to Law) | A.7.2.3 Discipline process |
| Corporate Communication (Crisis Management, Processes of Informing Board and Data Subject, Reputation Management etc.) | A.16 Information security incident A.17 Information Security Aspects of Business Continuity Management |
| Training and Awareness Activities (Information Security and Law) | A.7.2.2 Information security awareness, education and training |
| Register with VERBIS (Data Controllers' Registry Information System) | N/A |
The points stated in the tables above indicate that the Standard and the Law have controls over the same headings, however the terms and requirements of the controls are not exactly the same.
For example, while training and awareness activities are a control item in both aspects, the content and conditions of the training should be customized.
In addition, although the inventory preparation required within the scope of KVKK is also encountered in ISO 27001 as Inventory of Assets, it is not possible to state that an organization with an Inventory of Assets also has a Personal Data Inventory, as the conditions for the preparation of inventories differ from each other.
Our consultants offer you the most suitable solutions for your business in order to ensure your KVKK compliance and to provide you to have an ISO 27001 certificate by considering the similarities and differences. Besides, they carry out compliance processes and information security system setup at the same time, which enables ease of implementation.
Contact us to set up your information security system and determine the measures your business needs.
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