How Turkish Tech Firms Can Build Ethical AI: A Look at KVKK's Latest Guide
If your team is working on AI products in Turkey, there’s a new piece of guidance from KVKK (the Turkish Personal Data Protection Authority) that you need to pay attention to. The document “Recommendations on the Protection of Personal Data in the Field of Artificial Intelligence” is one of the clearest signals yet that AI ethics and privacy-by-design are no longer optional.
This isn’t just about compliance. It’s about building tech that earns trust from users, partners, and regulators alike.
Let’s break it down and show how it connects with broader trends, particularly the EU’s High-Level Expert Group’s Ethics Guidelines for Trustworthy AI (which many multinational firms already look to as a blueprint).
What’s New from KVKK?
KVKK’s guide outlines concrete steps AI developers, manufacturers, and service providers should take to protect personal data, especially in systems that rely heavily on machine learning or automated decision-making.
Here are the key takeaways for tech teams:
Start with risk. If your AI model processes personal data — especially sensitive data — you need to assess the privacy risks up front. KVKK recommends a privacy impact assessment (PIA) as early as possible.
Design with privacy in mind. Think privacy-by-design. Your models, data pipelines, and APIs should be built around minimizing data use, avoiding overreach, and supporting user control.
Make explainability real. Users (and regulators) have the right to know why a model made a decision. Black-box outcomes aren’t acceptable when personal rights are on the line.
Avoid profiling without accountability. KVKK is clear: decisions based only on automated processing, especially ones that significantly impact a person, must allow for human review or objection.
Don’t repurpose AI blindly. Using models or algorithms in new contexts (beyond their original intent) can introduce new risks. This is flagged as a red line in the guide.
How does this line up with EU Expectations?
These ideas mirror what we’ve already seen in the EU’s Ethics Guidelines for Trustworthy AI — a framework developed by an expert group advising the European Commission.
The EU model outlines three goals for AI:
Lawful – Follow all existing regulations.
Ethical – Align with human rights, fairness, and societal values.
Robust – Avoid unintended harm; ensure safety, security, and reliability.
They also lay out seven key areas for companies to act on:
Human oversight
Technical robustness and safety
Privacy and data governance
Transparency
Fairness and non-discrimination
Societal and environmental well-being
Accountability
It’s no surprise that KVKK’s advice echoes these points — Turkey has increasingly looked to international frameworks (like OECD and Council of Europe guidelines) to align local AI governance with global standards.
What This Means for Your Company
If you’re building or scaling AI solutions, whether in finance, healthtech, logistics, or e-commerce, this guidance isn’t theoretical.
Here’s what you can do now:
Revisit your data pipelines. Are you collecting more than you need? Can some of it be anonymized or removed entirely?
Map out automated decisions. Where is your system making calls without human input? Do users know that? Can they contest it?
Involve legal and product early. Compliance can’t be a post-launch patch. Align your dev roadmap with privacy and ethics checks from the start.
Document trade-offs. If your team made design choices that impact privacy, fairness, or explainability, keep a record. You’ll need it later.
This shift toward ethical, transparent AI isn’t just about aligning with laws — it’s about building credibility in a space where public trust is fragile and scrutiny is growing.
But interpreting these frameworks — and embedding them into how you design, train, deploy, and govern AI systems — isn’t straightforward. That’s where we come in.
At Arifoglu & Partners, we work closely with tech companies navigating the legal and regulatory edge of AI and data governance. Whether you're developing your first risk framework, preparing for a KVKK audit, or expanding into the EU, we help you translate abstract principles into operational safeguards that make sense for your business.
If you're building AI in Turkey, don't wait for regulation to catch up — start getting it right now.
Let’s talk.
