KVKK-Compliant AI Usage: What Should Companies Pay Attention To?

AI is increasingly used by legal, call center, HR, finance, and operations teams. However, if the documents transferred to AI systems contain personal data, a separate assessment must be made under KVKK.

As AI usage grows, so does KVKK risk

Even if a system appears to merely summarize a document, if that document contains names, national ID numbers, phone numbers, emails, addresses, IBANs, voice recordings, or customer information, personal data processing comes into play.

When does AI process personal data?

If an AI system works directly or indirectly with information relating to a real person, there is a risk of personal data processing. Call center recordings, case files, contracts, CVs, payrolls, health documents, and financial forms are high-risk documents in this respect.

Core principles for KVKK-compliant AI usage

Companies should apply the principles of lawfulness and fairness, specific and legitimate purpose, data minimization, accuracy, retention period, and data security to their AI processes as well. For example, in a contract where only payment obligations will be analyzed, transferring all identity data of the parties to the AI system may not be necessary.

Explicit consent is not always the answer

Basing the entire legal ground for AI usage on explicit consent is not always correct. The condition for data processing should be assessed according to the type of data processed, the purpose, the relationship between parties, and the process. Topics such as employee data, customer data, special categories of data, legal documents, and cross-border transfers should be examined separately.

What to watch for in cloud-based AI tools

Organizations should know in which country data is processed, whether it is shared with third parties, whether it is used in model training, and how long it is retained. If clear answers to these questions cannot be obtained, uploading sensitive data to general-purpose AI tools can create risk.

Why is anonymization critical?

Masking personal data before uploading a document to AI is an important step for data minimization and secure usage. Solutions like Redactra detect personal data in documents and support anonymization and reconstruction with dummy data.

A checklist for companies

The purpose of AI usage should be defined, the types of data processed should be identified, the legal basis should be evaluated, privacy notices should be updated, retention periods should be set, and logging should be performed. In addition, user access should be limited, extra security measures should be taken for sensitive data, and AI output should pass through human review.

Conclusion

Using AI is important, but using it securely is just as important. A KVKK-compliant AI approach considers data minimization, anonymization, secure infrastructure, access control, and human oversight together.