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Regulation on Processing of Land Registry and Cadaster Data and Transactions to be Made in Electronic Media ("Regulation") has been published in the Official Gazette No.31860 and dated June 8,2022 by the Republic of Türkiye Ministry of Environment, Urbanization and Climate Change. The Regulation determines the principles and procedures regarding the online processing of the data in the central database of General Directorate of Land Registry and Cadaster and the transactions to be made in the electronic media. Land Registry and Cadaster System ("TAKPAS") means a service that allows the data kept in the central database to be shared with institutions and individuals, a system consisting of Web Land Registry or other interfaces determined by the General Directorate; "Recipient" means the person or institutions benefiting from TAKPAS; "General Directorate" means General Directorate of Land Registry and Cadaster, "Protocol" means the access protocol to TAKPAS prepared in accordance Turkish Personal Data Protection Law dated March 24, 2016 and numbered 6698 and signed with institutions requesting land registry and cadaster data, professional organizations in the nature of public institutions limited to their own business, legal entities operating in real estate-related matters.
Confidential units and parts are units and parts of public institutions and organizations that create and store the "top secret" and "confidential" information and documents in accordance with the provisions of the Regulation on the Procedures and Principles to be Applied in Confidential Documents (In Turkish). Public institutions and organizations determine the confidential units and parts accordingly. However, of all public institutions and organizations; inspection and control units, personnel units, data processing units and private secretariat are considered as confidential units.
It has been stated that accessing the real estate information of the citizens by entering only the Turkish Republic ID number on the real estate tax payment/fast payment and debt inquiry pages submitted online by the municipalities in various notices conveyed to the Turkish Data Protection Authority ("Authority") causes a problem in terms of protection of personal data and it has been requested to be examined within the scope of Turkish Data Protection Law No. 6698 ("KVKK").
As it is known, Art. 16 of the Turkish Data Protection Law ("KVKK") numbered 6698 states that "Natural and legal persons who process personal data shall register with the Data Controllers Registry prior to the start of data processing" and with the provision "Data controllers are obliged to register Data Controllers’ Registry Information System ("VERBIS") within the period determined and announced by the Authority" provision is included.