emirms/turkish-data-protection-authority-decisions

Turkish Data Protection Authority (Kişisel Verilerin Korunması Kurulu / KVKK) Decisions & Breach Register

Every Board decision published by Turkey's data protection regulator (KVKK, Law No. 6698), plus a supplementary register of its published data-breach material — one row per decision, one row per breach event, with derived structural metadata and a coverage proof.

393 decisions · 79 breach-register rows · two configs · 2017–2026

Why this dataset is not a bigger one

The sibling release in this series, the Turkish Competition Authority dataset, is 10,367 decisions and 323 million characters of full text, because the Competition Board publishes the complete text of every decision it makes. KVKK does not. Only 59 of these 393 decisions (50 board + 9 principle decisions) carry a full decision text; the other 334 are the regulator's own published summaries (Karar Özeti, 329 rows) or announcement pages (5 rows). Trying to match the competition dataset's scale would invite the comparison and lose it. This dataset leads instead on provable coverage and corrected structure — properties that are genuinely stronger here than a bigger, less-audited corpus would be:

1. Coverage is proved with two independent set differences, not a single arithmetic sum. Discovery is the union of KVKK's paginated decision listing (37 pages, 314 distinct raw hrefs → 303 resolved decision numbers) and the site's own search index (25 pages, 356 distinct raw hrefs → 342 resolved decision numbers for karar özeti alone) — 348 discovered numbers in total. A build refuses to export if either of two checks fails, and both are currently empty: missing_from_dataset (a number the live listing/search enumeration finds that isn't in the dataset and isn't a recorded dead link — a true coverage hole) and off_listing_unjustified (a published decision the enumeration can't find, that also doesn't fall into a justified off-listing category or a reviewed archival note — see below). A parallel, independent reconciliation exists on the breach-announcement side too (17 discovered = 16 published + 1 excluded for privacy, see below) — and it is a real exhaustion, not a lucky early stop: the search sweep now walks all 7 pages of results (an earlier version stopped at page 3), with page 1 returning 13 matching announcements, page 2 the remaining 4, and pages 3–7 contributing zero new ones. That walking-to- genuine-exhaustion is what lets 17 stand for the whole set rather than an early-stopped sample; it happens to find the same 17 the earlier, truncated sweep already had, so no new announcement surfaced from the fix — the old bug had, by luck, already caught all of them.
2. KVKK's own listing does not show 45 decisions that its own search engine does. Of the 375 published rows that carry a resolved decision number, 300 sit in the paginated listing itself; 45 more are absent from the listing but independently verifiable via KVKK's own search today — for example 2022/1152, 2022/1407, 2023/1610, 2023/2185, 2023/412 and 2024/133, all published the same day, 10 Ağustos 2026, and all missed by the listing walk while the search sweep found them. 2023/412 is itself a breach-notification decision. This is the headline claim of this release, and it is checkable in about a minute by re-running KVKK's own search box on any of the six numbers above.
3. A further 30 published decisions are found by neither route today — a quieter, separate fact from the 45 above, and not evidence of anything findable by search. 29 are automatically justified by category: they are full_text manifestations, principle (ilke kararı) decisions, or both — types KVKK itself publishes outside the ordinary karar özeti listing/search, so their absence from that listing/search is expected, not a gap. The last one, 2025/1572, is held for individual review: its only surviving manifestation is a Kamuoyu Duyurusu clarifying how an earlier board decision is to be applied, not a karar özeti itself, and is logged with the evidence in provenance/held_but_no_longer_discoverable.jsonl rather than silently waved through.
4. A regulator contradiction, resolved and logged. For the decision at Icerik/6924/2020-118, the URL slug and the page title both say 2020/118, while KVKK's own "Karar No" table cell on the same page says 2021/118. This dataset follows the slug and title (2020/118) and records all three candidate values and the reason in provenance/corrected_numbers.jsonl.
5. 3 decisions KVKK's own listing links to but cannot serve — 2019/47, 2019/52, 2019/122 — all soft-404 at the regulator (a 200 response whose final page is the homepage, per KVKK's own redirect behaviour). These are recorded as unreachable, not dropped from the count, so the coverage denominator stays honest.
6. 25 rows excluded and each rule stated. 13 by title shape (Çerez Aydınlatma Metni ×3, 2026 KVKK Çocuk Takvimi ×3, Duyurular announcement-index pages ×5, conference-news pages ×2) and 12 by failed PDF extraction (under 200 characters of real text once [sayfa N] page markers are stripped). One of the title-shape exclusions had wrongly acquired the decision number 2019/308 — it is KVKK's own "Duyurular" index page, not a decision.

The provenance/*.jsonl/.json files cited throughout this card (here and below) are audit artefacts from the build repository, not part of this Hugging Face upload — see "How these numbers were produced" for why.

Two configs

config	rows	what it is
decisions	393	one row per KVKK Board or principle decision, manifestations merged
breaches	79	a supplement, not the headline: KVKK's own breach announcements plus decisions whose title or subject explicitly concerns a personal-data breach

The breach register is a supplement, and its fields are sparse — say so plainly. KVKK only began publishing standalone breach announcements (kamuoyu-duyurusu-veri-ihlali-bildirimi-*) in 2026; before that, breach matters surface only as ordinary decision summaries, which are frequently anonymised by the regulator itself (e.g. "bir e-ticaret platformu") and rarely state an affected-person count or a detection date. Several fields in the breaches config are filled well under half the time. That is the regulator's own publication practice, not a defect in extraction — the fields below state the real percentages.

Fields

decisions — 31 fields

field	type	source	fill	notes
decision_id	string	derived	100%	decision_number if resolvable, else doc:<canonical_id>
decision_number	string	regulator	95.4%	authority order: URL slug → metadata table → asserting-context title citation → null
decision_year	int64	derived	95.4%	parsed from decision_number; year-gated 2017–2026
decision_seq	int64	derived	95.4%	parsed from decision_number
decision_date	string (ISO)	regulator	93.6%
publication_date	string (ISO)	regulator	98.0%
decision_type	string board|principle	regulator	100%	380 board, 13 principle
publication_type	string full_text|summary|announcement	derived	100%	59 full_text, 329 summary, 5 announcement
title	string	regulator	100%
subject_summary	string	regulator (Konu Özeti)	86.3%
full_text	string	regulator	100%	the regulator's own summary or announcement text for 334 of the 393 rows — see above
char_count	int64	derived	100%
facts	string	derived	36.4%
defence	string	derived	10.9%
board_assessment	string	derived	32.1%
holding	string	derived	76.8%
administrative_fine_try	float64	derived	33.3%	null means no amount was extracted, not that no fine was imposed — see below
administrative_fine_currency	string	derived	33.3%	always TRY where non-null
cited_law_articles	list[string]	derived (6698:12)	55.7%	articles of Law 6698 only
cites_decisions	list[string]	derived	18.6%	asserting-context citations only, self-citations dropped, gated to resolved numbers
publication_order	bool	derived	5.3%	the Board's own holding explicitly orders the decision published (Resmî Gazete or KVKK's site); only true is ever recorded, never false
is_breach_related	bool	derived	100%	the strict D6 rule below; 63 rows true
source_url	string	regulator	100%
source_urls	list[string]	regulator	100%	every merged manifestation's URL
source_host	string	regulator	98.5%	see "One resolvable source host", below; 6 rows (1.5%) unresolved
manifestation_count	int64	derived	100%	4 decisions merge two published manifestations each
sha256	string	derived	100%	of the primary manifestation's source bytes
source_sha256s	list[string]	derived	100%
fetched_at	string (ISO)	derived	100%
snapshot_cohort	string	derived	100%	backend-2026-07-13 (346 rows) or kvkkdata-2026-08-27 (47 rows fetched for this release)
extraction_warnings	list[string]	derived	0.8%	3 rows (2019/353, 2019/254, 2019/204) flagged short_full_text — each survives the harder exclusion gate but publishes under 400 characters (placeholder "Yeni Yayınlanan Karar Özeti" titles); kept, not dropped, and flagged here for a human to look at rather than silently reclassified

Not shipped, deliberately. fine_imposed (a boolean would misstate a partial extraction as a fact — see below) and nine backend columns that are 0.0% filled across the source data and would add nothing but noise: complaint_type, applicant_type, respondent_type, sector, orders, corrective_measure, compliance_deadline, unanimous_or_majority, dissent_present.

breaches — 22 fields

field	type	source	fill	notes
breach_id	string	derived	100%
breach_source	string announcement|decision_summary	derived	100%	16 announcement, 63 decision_summary
announcement_date	string (ISO)	regulator	20.3%	non-null only on announcement rows
controller_name	string	regulator, rule-filtered	26.6%	verbatim only for the 21 names classified as organisations — see below
controller_is_organisation	bool	derived	26.6%	true wherever controller_name is non-null
decision_number	string	regulator	79.7%	non-null on decision_summary rows
authorising_decision_number	string	regulator, asserting context	20.3%	never resolves into decisions — see Known limitations
authorising_decision_date	string (ISO)	regulator	20.3%
breach_detected_date	string (ISO)	regulator	27.8%
breach_start_date	string (ISO)	regulator	16.5%
notified_to_authority_date	string (ISO)	regulator	3.8%
affected_person_count	int64	regulator	40.5%
affected_person_count_is_exact	bool	derived	40.5%	false when the text says yaklaşık/civarında, or that the count is still being determined
affected_data_categories	list[string]	regulator	16.5%
affected_person_groups	list[string]	regulator	20.3%
breach_cause_excerpt	string	regulator, verbatim span	44.3%	a quoted span from the source text — not a classification label; 35 breach-era rows across two drafting eras cannot support a defensible closed taxonomy
full_text	string	regulator	100%
source_url	string	regulator	100%
sha256	string	derived	100%
fetched_at	string (ISO)	derived	100%
snapshot_cohort	string	derived	100%
extraction_warnings	list[string]	derived	20.3%

Design decisions worth knowing

The breach flag (is_breach_related) is strict, and the loose count is published alongside it, not included. A decision joins the breach register iff its title or subject summary matches veri ihlal[i]? bildirimi (63 rows), or it is a kamuoyu-duyurusu-veri-ihlali-bildirimi-* announcement page (16 rows) — 79 rows total. A further 13 decisions mention the phrase only in the body, typically reciting the Article 12(5) notification duty in passing rather than describing an actual breach; those are counted (92 rows, the loose total) and reported in provenance/coverage.json, but excluded from the published register. Including them would make "the KVKK breach register" mean something the regulator did not itself publish as one.

authorising_decision_number never resolves against decisions, and this is by design, not a bug to be joined around. All 16 announcement rows carry it — it is the Board decision that authorised publishing the announcement itself, not the breach decision. Those authorising decisions are procedural housekeeping and are not published in karar özetleri; they are not in this dataset and never will be. Every one of the 16 non-null values is listed in provenance/coverage.json's unresolved_join_keys precisely so a user who tries that join gets a documented zero, not a silent one.

Controller names: publish the organisation, exclude the person — do not pseudonymise them side by side. 22 distinct controller names were reviewed (provenance/controller_classification.jsonl, approved as Gate G1 by the dataset owner, 2026-08-27). 21 carry a recognised organisation-form token (A.Ş., Ltd. Şti., Anonim Şirketi, Limited, and others) and are published verbatim. One is a natural person. That person's breach row is excluded from the dataset entirely, not pseudonymised — KVKK's own URL slug for that announcement spells the person's name, and the URL must remain a working citation, so a pseudonym sitting next to a name-bearing URL would be worse than either publishing the name or dropping the row. A related leak (the same person's e-mail address, in de-diacriticised form, surviving inside full_text) was found and fixed before this release. Verified directly against the shipped data for this card: a full-corpus scan of both jsonl files for the person's name and its variants returns zero matches, and breaches.jsonl contains exactly 79 rows, confirming the excluded row is gone, not merely masked. Export itself now refuses to run if that name (or any un-pseudonymised organisation classification) reappears — kvkkdata export gates on pseudonymise.assert_export_is_clean() before it writes anything, not only at the earlier pseudonymise step.

administrative_fine_try is nullable, with no fine_imposed companion. The extractor takes the first explicit TL amount stated near "idari para cezası" and stops. Decisions routinely impose more than one fine (Articles 12(1) and 12(5) separately), so a null here means no amount was extracted, not that no fine was imposed, and a non-null value may capture only the first of several. Fill is 33.3% (131/393); the extracted amounts range 18,000–3,250,000 TRY.

One resolvable source host, not two. 387 rows (98.5%) are hosted on kvkk.gov.tr — 357 on www.kvkk.gov.tr and 30 on the bare kvkk.gov.tr form — and 6 rows (1.5%) carry no resolvable host. No row in this build is hosted on resmigazete.gov.tr. The 13 principle decisions (ilke kararı) in this dataset are themselves originally published as Resmî Gazete PDFs, but every one of those PDF manifestations that this build encountered failed automated text extraction (under 200 characters of real content, mostly [sayfa N] page markers) and was excluded (provenance/excluded_decisions.jsonl); the manifestation that actually ships for each principle decision is a kvkk.gov.tr-hosted announcement or full-text page instead. Two of those merges — 2026/347 and 2026/921 — keep a KVKK Kamuoyu Duyurusu announcement (correct title, correct type) over the original Resmî Gazete text precisely because that original PDF extraction failed; the excluded PDF's own URL lives only in provenance/excluded_decisions.jsonl's url field, not in the published row's source_urls, so it is not reachable from the dataset row itself.

Cited-article and cited-decision extraction is asserting-context only. cited_law_articles accepts only articles of Law 6698 (the pattern 2016/679, the EU GDPR's own number, is explicitly rejected, never mistaken for a KVKK decision). cites_decisions accepts only a decision number following an explicit citation phrase (<date> tarih ve <number> sayılı … Kurul kararı); a bare YYYY/NNN scan over decision prose is never used, because it would invent decisions out of statutory and case citations.

Known limitations

• This is a small, summary-heavy dataset next to its sibling. Only 59 of 393 rows (15.0%) carry full decision text; 329 are the regulator's own published Karar Özeti and 5 are announcement pages.
• The breach register is sparse by the regulator's own publication practice, not by extraction failure. Several fields are filled under 30% of rows — see the table above; none are rounded up.
• 18 of 393 rows (4.6%) carry no resolvable decision number at all and so sit on neither side of the coverage reconciliation, by construction — they can be neither "discovered" nor "off-listing" without a number to match on.
• 3 decisions are recorded unreachable, not silently dropped: 2019/47, 2019/52, 2019/122 all soft-404 at KVKK today.
• 1 decision is held for individual review, not counted as archival or search-findable: 2025/1572's surviving manifestation is an implementation-clarification Kamuoyu Duyurusu, not a karar özeti — it is absent from every saved listing and search page this build captured, logged with the evidence in provenance/held_but_no_longer_discoverable.jsonl.
• 25 rows excluded, each with the rule that fired (provenance/excluded_decisions.jsonl) — 13 by title shape (Çerez Aydınlatma Metni ×3, 2026 KVKK Çocuk Takvimi ×3, Duyurular announcement-index pages ×5 — including one page that had wrongly acquired the decision number 2019/308 — and conference-news pages ×2) and 12 by failed PDF extraction (Devamını Gör/Mehr lesen placeholder titles and other under-200-character Resmî Gazete PDF extractions).
• One decision number is a regulator-side contradiction, resolved and logged: 2020/118 per slug and title vs. 2021/118 per KVKK's own "Karar No" table cell (provenance/corrected_numbers.jsonl).
• administrative_fine_try captures only the first stated amount — see above.
• cites_decisions and authorising_decision_number are gated, not exhaustive — unresolved or unasserted candidates are dropped, not kept with a maybe-flag.
• Nine backend fields were not shipped because they are 0.0% filled in the source data (see the decisions fields table).

Composition

decisions, by type: 380 board · 13 principle. By manifestation: 59 full_text · 329 summary · 5 announcement.

decisions, by decision year (decision_date, 368/393 resolved; 25 rows have no decision date):

year	n
2017	2
2018	17
2019	38
2020	97
2021	71
2022	53
2023	52
2024	26
2025	7
2026	5

Most-cited articles of Law 6698: 18 (administrative sanctions, 133), 12 (data-security obligations, 125), 5 (processing conditions, 71), 4 (general principles, 36), 3 (definitions, 35).

breaches: 16 announcement rows · 63 decision-summary rows (79 total, strict); a further 13 body-only matches are reported but not included (92, loose).

Usage

from datasets import load_dataset

decisions = load_dataset("emirms/turkish-data-protection-authority-decisions", "decisions")
breaches  = load_dataset("emirms/turkish-data-protection-authority-decisions", "breaches")

# decisions explicitly about a personal-data breach
breach_decisions = decisions.filter(lambda r: r["is_breach_related"])

# decisions the Board ordered published (candidate precedent decisions)
to_publish = decisions.filter(lambda r: r["publication_order"])

# fined decisions — remember a null does not mean no fine was imposed
fined = decisions.filter(lambda r: r["administrative_fine_try"] is not None)

# do NOT attempt this — it will silently return nothing:
# breaches.filter(lambda r: r["authorising_decision_number"] == some_decision_number)

Do not join breaches.authorising_decision_number against decisions — by design it never resolves (see above). Join breaches.decision_number against decisions.decision_number instead, for the 63 decision_summary rows.

Collection method

Fetched entirely from www.kvkk.gov.tr (see "One resolvable source host, above" — the Official Gazette PDFs behind the 13 principle decisions were attempted but their extractions failed and were excluded, not shipped as a second host). The dataset combines a prior full crawl of the listing-discoverable corpus (346 decisions, snapshot cohort backend-2026-07-13) with a targeted, search-based fetch of 47 further decisions on 2026-08-27 (kvkkdata-2026-08-27) — decision numbers the union of the listing walk and the search sweep newly surfaced beyond that prior crawl. Of those 47: 41 sit on today's listing and 6 are the search-only headline decisions named above (2022/1152, 2022/1407, 2023/1610, 2023/2185, 2023/412, 2024/133) — this fetch is exactly where those six were pulled from (provenance/fetch.log). None of the 47 belong to the 30-row off-listing set: that set is, by definition, published decisions the live enumeration cannot find today, so a fetch driven by that same enumeration could never have reached them — the 30 were confirmed by individual review and category rule, not by re-fetching. The targeted fetch ran at a minimum 2.0-second spacing between requests, honouring Retry-After, over 67 requests (50 decision candidates, 17 breach-announcement pages). 47 of the 50 decision candidates fetched cleanly; 3 soft-404'd at the source and are recorded as unreachable, not dropped.

Coverage is a reconciliation, not an assertion: the site's own paginated listing walk, its search-index totals (Toplam: N sonuç bulundu., captured per query), and the discovered∪published set differences are cross-checked against each other, and kvkkdata export refuses to run if either direction comes back non-empty (DiscoveryGapError, UnexplainedOffListingError) — a parallel reconciliation exists for the breach-announcement sweep too.

How these numbers were produced

Every number in this card is read from a provenance file, or derived directly from the shipped data and the raw evidence files a provenance step already saved — never typed by hand. These provenance/* files are part of the build repository that produced this dataset, not part of the Hugging Face upload itself — only the two decisions/breaches parquet files and this card ship here. They are cited below so every figure in this card is traceable to its source and, in principle, reproducible from the same evidence a reviewer would need — not as links a reader can click from this page. Several of them (G1_SIGNOFF.md, controller_classification.jsonl, excluded_breaches.jsonl) necessarily name the one natural person excluded from this dataset, because a record of "we removed X" has to say who X is — that is exactly why they are not published alongside the data.

number(s)	source file
393 decisions, 79 breach rows, all per-field fill percentages	provenance/fill_rates.json
listing/search totals (37/25 pages, 314/356 distinct raw hrefs), the 348/375/3 discovery-reconciliation figures, the 30/29/1 off-listing split, source-host and snapshot-cohort breakdowns, the 16 unresolved authorising_decision_number join keys, the 63/16/79/13/92 breach counts	provenance/coverage.json
the 303 listing-resolved / 342 search-resolved decision numbers, the 300-on-listing vs. 45-search-only split within the 375 published numbers, and the per-category (full_text/principle) breakdown of the 30 off-listing rows	derived directly from provenance/listing_pages/kurul_karar_ozetleri/*.html and provenance/listing_pages/decision_search/*.html, re-parsed with the project's own parse_listing_items/parse_search_result_items/discovered_decision_number, cross-referenced against data/decisions.jsonl — these two splits are not stored as a single field in coverage.json and were reconstructed for this card
the 25 excluded rows and the rule each fired	provenance/excluded_decisions.jsonl
the 1 decision held for individual review (2025/1572)	provenance/held_but_no_longer_discoverable.jsonl
the 2020/118 vs 2021/118 contradiction	provenance/corrected_numbers.jsonl
the 22 controller-name classifications and the G1 sign-off	provenance/controller_classification.jsonl, provenance/G1_SIGNOFF.md
the excluded natural-person row and why	provenance/excluded_breaches.jsonl
the six named off-listing decisions, their dates and breach status; the administrative-fine range; article, decision-type, publication-type and year distributions; the manifestation-merge count and the 2026/347/2026/921 merge tradeoff	direct read of data/decisions.jsonl / data/breaches.jsonl

Licence and reuse

The underlying decisions and announcements are public regulatory material published by Turkey's Personal Data Protection Authority. This dataset is a faithful compilation of that public material with derived structural metadata; no editorial content has been added to the decision or announcement texts. As with the sibling Competition Authority dataset in this series: FSEK Art. 31 exempts kazai kararlar (judicial decisions) from copyright, and Board decisions here are administrative rather than judicial, so that provision does not straightforwardly apply; this compilation is published on the basis that the material is official public-sector information made freely available by the authority.

One natural person's controller name (and the corresponding breach row) has been excluded from this dataset in full — see above. No other redaction has been applied to full_text; it is not otherwise a byte-identical copy check against source PDFs (KVKK publishes most of these as HTML pages, not PDFs; the Official Gazette PDFs behind the 13 principle decisions failed automated extraction and were excluded rather than shipped partially). Users processing full_text should assume it may name individuals other than the excluded controller (complainants, respondents, officials) and are responsible for their own compliance with applicable data protection law, including Turkey's own KVKK (Law No. 6698) and, where relevant, the GDPR.

Versions

• v1.0 (2026-08-27) — initial release. Two configs: decisions (393 rows, 31 fields), breaches (79 rows, 22 fields).

This is an archive of public regulator material. It is not legal advice.

Citation

@dataset{turkish_data_protection_authority_decisions_2026,
  title  = {Turkish Data Protection Authority (KVKK) Decisions \& Breach Register},
  author = {Sezer, Emir Murat},
  year   = {2026},
  note   = {393 decisions, 79 breach-register rows, with a reconciled coverage proof},
  url    = {https://huggingface.co/datasets/emirms/turkish-data-protection-authority-decisions}
}