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.
Founder Academy resources
Free, practical checklists for this area: VERBİS Registration Checklist, KVKK Tracker.
Frequently Asked Questions
What does a KVKK audit actually check?
The gap between paper and practice: whether processing records match real data flows, notices reflect what systems do, consents are valid and logged, retention schedules are enforced, technical and administrative security measures exist, and vendor contracts contain the right processing terms. Documentation that contradicts practice is worse than no documentation.
How often should we audit?
Annually as a baseline, plus after any significant change — new product lines, new vendors or analytics stacks, M&A, or reorganisations. The Board’s accountability expectation means you should be able to show recurring review, not a one-time project from two years ago.
What happens if the Board opens an investigation?
You receive detailed information requests with short deadlines; responses become the record on which fines are based. Having a current audit file — inventory, measures, decisions log — converts a scramble into an administrative exercise. Complaint-driven investigations are the most common trigger, usually from ex-employees or customers.