Transparency and privacy notices under KVKK and RGPD: where do we start from scratch?

The biggest misconception is confusing the privacy notice with explicit consent. A privacy notice is not a consent-seeking document; it is a notification telling the other party, 'I process your data under these rules.' Therefore, putting an 'I have read and agree' checkbox under the text is legally incorrect; it simply needs to be accessible.

You mentioned collecting allergy information, which is a critical point. Under both KVKK and RGPD, health and dietary sensitivities are considered special category personal data. Merely providing a general privacy notice is not sufficient to process this data; you must obtain explicit consent, limit the retention period to the event itself, and keep it encrypted in your database.

Something you can easily do first thing tomorrow: instead of a checkbox below the quote request form on your website, add a link that reads, 'By submitting this form, you acknowledge that you have reviewed the Personal Data Processing Privacy Notice.' Until you draft the full text, you will at least have initiated the transparency step at the touchpoint.

edit: typed from phone, sorry for typos.

Are you storing data belonging to clients in Turkey on servers in France or is data from clients in France being transferred to Turkey? If there is a cross-border data transfer you are required to explain the recipient countries and legal safeguards under a separate heading in the privacy notice.

Don't trust online automatic policy generators. Most are translations of 'privacy policies' drafted under American law. Neither the supervisory authority in France nor your corporate client's legal department will accept those templates. You really need to write a simple text tailored specifically to your operation.

As a legal entity operating in France, your primary obligation is compliance with RGPD and CNIL regulations. Under the law, you must explicitly state a dedicated email address in the privacy notice where data subjects can submit requests to exercise their rights of erasure, rectification, and access.

When starting from scratch, follow these three steps: 1) Create a one-page inventory table categorizing collected data by purpose, 2) Draft a plain-language, layered privacy notice based on this inventory, 3) Permanently place a link to the notice at the bottom of forms and proposal PDFs.

Don't let it overwhelm you at all. Corporate clients usually just want to see that you take the matter seriously. Once you have a basic notice in place and set sensible retention periods you'll pass their audit with no problem.

I agree with this. Mistakes made on the kvkk transparency privacy notice side are usually reversible but expensive.

We need to take it step by step. When you try to change everything at once, nothing settles.

you're right. an automated scan report is not the same as a penetration test.

proven by experience.

This thread is archived.

I agree with this. If permission and scope aren't in writing, don't start that test.

Good luck with that.

Could you elaborate on that? Solutions that work at a small scale collapse when you grow; I learned this late.

When making decisions, write down the worst-case scenario too, not just the best. Hope this helps.

quick summary for newcomers: The biggest time-waster for us was not knowwing who had the final say.

if it's your first time, start small; scaling comees later.. then honestly of course, it varies if your situation is different.

This is exactly what we experienced. The harder it is to reverse a decision the slower you should make it.

Proven by experience.

I was thinking the same thing. Everything goes well for the first three months; problems arise in the fourth.

Don't hesitate to ask; those who don't ask always pay more. If you post the result here, it will help others too.

i'm curious too.