A KVKK compliance program looks good on paper until the first regulator visit, customer audit, or M&A diligence request — and then the gaps surface. Vircon Legal conducts independent KVKK audits for operating companies, investment targets, and acquisition candidates: structured assessments that produce a defensible compliance posture, not a vague memo.
What a Vircon KVKK audit covers:
- Data inventory and flow mapping. Comprehensive record of personal data categories, processing purposes, retention periods, and cross-border transfer paths — aligned with VERBİS registration realities.
- Lawful basis review. Article-by-article analysis of consent, contract, legitimate interest, and explicit-consent reliance across product lines.
- Vendor and sub-processor audit. DPA inventory, sub-processor classification, and gap analysis against current contract paper.
- Notice and consent audit. Privacy notice multi-layer assessment, consent UX review, dark-pattern detection.
- Technical and organizational measures (TOM). Access controls, encryption posture, retention enforcement, and incident response readiness review.
- Cross-border transfer assessment. SCC adoption status, BCR application paths, and Schrems II-style analysis for US destinations.
- Data subject rights workflow audit. Response-time tracking, request classification, and verification protocols.
- Findings report and remediation roadmap. Prioritized findings with severity scoring, remediation timeline, and ongoing monitoring recommendations.
We perform KVKK audits as part of M&A due diligence (coordinated with our M&A practice), as part of pre-fundraising diligence prep, and as standalone health checks. Companies seeking to maintain ongoing readiness use our KVKK Tracker as a continuous self-assessment tool. For full compliance program design, see our KVKK & GDPR Compliance practice.