A KVKK Guide for Digital Agencies
Digital agencies handle large amounts of personal data in campaign management, CRM integration and remarketing. Under KVKK, they therefore generally act as “ data processors ”. However, many…
Digital compliance & KVKK • 2025 guide
Digital agencies handle large amounts of personal data in campaign management, CRM integration and remarketing. Under KVKK, they therefore generally act as “data processors”. However, many agencies unknowingly assume the role of data controller, exposing themselves to legal risks.
Summary: The basic principle for agencies: “If you process data on behalf of a client, you are a processor; if you make decisions for your own purposes, you are a controller.”1. Campaign data and the scope of KVKK
- Form data collection: Data collected through web forms, such as names, email addresses and phone numbers, falls within the scope of KVKK.
- Remarketing: IP addresses and behavioural data from pixel- and cookie-based tracking are considered personal data.
- Analytics platforms: Check how data processed in tools such as Google Ads, Meta and LinkedIn is transferred and shared.
- Agency dashboard access: If the agency can access client systems, its data-processing activities must be documented.
“Every click is data; every piece of data creates an obligation.”
2. Agencies as data processors
| Area | Agency role | Obligation |
|---|---|---|
| Campaign Management | Acts on the controller’s instructions | Sign a DPA (data processing agreement) |
| CRM Integration | Processes the data but does not own it | Store access logs |
| Analytics & Reporting | Processes collected data and produces reports | Apply anonymisation or masking |
3. Compliance points for forms and campaign processes
- Obtain written instructions from the client at the start of the campaign.
- Both parties should sign a data processing agreement (DPA).
- Forms should include a privacy notice and an explicit-consent checkbox.
- Data must be deleted or delivered to the customer at the end of the campaign.
“Deleting data is the final step in secure campaign management.”
4. Example of the B10 compliance protocol
B10 Digital Agency applies a standard “Data Processing Compliance Protocol” in all campaign partnerships. This protocol transparently defines the agency–brand relationship:
| Section | Content |
|---|---|
| 1. Definitions | Definitions of controller, processor and special-category personal data |
| 2. Purpose | Limiting data processing activities in campaign processes |
| 3. Obligations | Agency's data security measures and obligation to delete |
| 4. Audit | The brand’s right to audit agency processes |
| 5. Breach notification | Obligation to notify the data controller within 72 hours |
5. How to build a culture of compliance in an agency
- All teams must receive KVKK awareness training,
- Sign the data policy during new-client onboarding.
- Shared data must be accessible only to authorized persons,
- Data retention policies in cloud services should be regularly reviewed.
Make your agency compliant with KVKK.
B10 Digital Agency provides lasting data security through KVKK compliance protocols, consent wording and DPAs designed for digital agencies.
Yes, but only if you process data for your own purposes, for example when providing marketing analytics services. If you process data on behalf of the client, you act as a processor.
Do we have to delete form data at the end of the campaign?Yes. Under Article 7 of KVKK, data must be deleted, destroyed or anonymised when the purpose of processing ends.
Is remarketing data personal data?Yes. IP addresses, cookie IDs and user-behaviour data are considered personal data. Their use should therefore be clearly described in the cookie policy.
Tags: KVKK • digital agency • data processor • remarketing • DPA • B10 Digital Agency
Sources and related documents
These documents provide references for the methods and rules discussed in this article.