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Legislation - CottGroup Holistic Business Services

21August2026

Five-Year Retention of Employee Emails and Conditions for Access: The Garante's Decision

The Italian data protection authority Garante Per La Protezione Dei Dati Personali ("Garante") imposed an administrative fine of EUR 460,000 on Piaggio & C. S.p.A. by its decision dated June 18, 2026 and numbered 2026/476. The decision concerns the retention of corporate email accounts allocated to former employees for five years, the retrospective review of such correspondence for use in disciplinary proceedings, and the failure to respond to data subject requests.

Author Ezgi Anasız, Category Personal Data Protection Law

17August2026

KVKK Compliance Period for Loyalty Programs Extended to February 28, 2027: How Should Companies Use the Additional Compliance Period?

The Personal Data Protection Board's ("Board") Principle Decision dated February 10, 2026 and numbered 2026/266 regarding the processing of personal data within the scope of loyalty programs was published in the Official Gazette dated February 28, 2026 and numbered 33182. The six-month compliance period granted to data controllers under the Principle Decision for the purpose of implementing the necessary technical and organizational measures will be expired on February 28, 2026.

However, this period has been extended until February 28, 2027 by the decision of the Board published in the Official Gazette dated August 13, 2026 and numbered 33339.

Author Ezgi Anasız, Category Personal Data Protection Law

11August2026

The Era of the Accompanying Person/Dependent Document in Foreign Nationals' Health Activation Procedures

Following the Regulation Amending the Temporary Protection Regulation, published in the Official Gazette No. 33091 dated 28 November 2025, important changes have been introduced in practice regarding the documents required for the health activation procedures of foreign nationals.

In this context, where family relationship or the dependent relationship cannot be established through other documents, the "Applicant and Accompanying Person Information (Accompanying Person/Dependent) Document" issued by the Presidency of Migration Management has also been included among the documents that may be used in health activation procedures.

Author Selma Kıy, Category Social Security Law and Legislation

07August2026

Beneficial Ownership Notification for General, Ordinary & Non-Share Limited Partnerships

Pursuant to General Communiqué on the Tax Procedure Law No. 529, certain categories of taxpayers other than corporate income taxpayers are required to resubmit their beneficial ownership information electronically to the Turkish Revenue Administration by the end of August each year.

Author Selma Kıy, Category Taxation Law

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