Turkey’s Personal Data Protection Authority (KVKK) has released its most detailed guidance to date on the risks, obligations, and legal considerations surrounding generative artificial intelligence, marking a significant step in the country’s efforts to regulate emerging AI technologies. The “Generative Artificial Intelligence and Personal Data Protection Guide (15 Questions)” outlines how Turkey’s existing data protection law applies to the full lifecycle of generative AI systems—from data collection and model training to deployment and user interaction.
The 63-page guide begins by defining key concepts such as large language models, neural networks, deepfakes, and foundation models, underscoring that generative AI systems rely on vast datasets that often include personal information. It warns that personal data may be processed at multiple stages even when not immediately apparent, including during web-scraped data collection, fine-tuning, and user prompts submitted to AI tools.
KVKK emphasizes that the risks of generative AI extend well beyond inaccurate outputs. The guide identifies potential harms including hallucinations, bias, discriminatory content, privacy breaches, data leakage, and intellectual property violations. It also highlights the danger of deepfake technologies, which can be used to fabricate convincing images, voices, and videos that threaten individuals’ reputations and public trust.
Regulators stress that developers and organizations deploying generative AI must comply with Turkey’s Law No. 6698 on the Protection of Personal Data. This includes clearly defining data-processing roles, ensuring transparency, applying privacy-by-design principles, securing legal bases for data processing, and implementing strong security safeguards. The guide further instructs companies to assess international data transfers, protect children using AI tools, and provide mechanisms for individuals to exercise their legal rights.
By publishing the guide, KVKK positions Turkey among a growing group of nations taking proactive steps to govern the rapid spread of generative AI technologies. The authority says the aim is to ensure innovation proceeds responsibly while strengthening public trust in AI-enabled services.
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