A KVKK Guide for Marketing Teams: Compliance Protocols for Year-End Campaigns

⏱️ Reading time: 13 min · 📁 Category: KVKK, Digital Marketing & Compliance

A KVKK Guide for Marketing Teams: Compliance Protocols for Year-End Campaigns

Because of discounts, campaigns, prize draws, loyalty programmes and intensive digital advertising, December is
the period with the fastest increase in personal data processing.
This intensity makes marketing teams one of the most risky functions in terms of KVKK.

The KVKK Board’s 2024–2025 decisions show that most year-end campaign breaches result from quick, non-compliant actions driven by marketing reflexes rather than deliberate breaches.

This guide helps marketing teams run promotions and prize draws without revenue loss and in full compliance with KVKK.

The most frequent audit finding for marketing activities is: Violation of the principles of purpose limitation and data minimisation. 1. Why Are End-of-Year Campaigns High Risk in terms of KVKK?

During December campaigns, multiple data processing activities are conducted simultaneously:

• Discount and promotional registration forms
• Prize draw entry applications
• Email and SMS messages
• Targeted advertising campaigns
• Loyalty programme scoring
• Landing page and microsite tracking

Each of these activities requires different legal bases. However, in practice, most marketing teams try to manage the entire process with a single text of "explicit consent".

This approach creates a high risk of KVKK breaches.

2. Common KVKK mistakes in promotions and prize draws Error 1: Unnecessary data collection

The following data is often unnecessarily requested for prize draws or campaigns:

• Turkish national identity number
• Date of birth (day/month/year)
• Full address
• Gender
• Occupation

The Board’s position is clear: Data not necessary for the campaign’s purpose is considered unlawfully processed.

Mistake 2: requiring marketing permission to enter a prize draw

Common but clearly illegal practice:

You must consent to commercial electronic messages to enter the prize draw.

This is invalid under KVKK and ETK together. Prize draw entry and marketing permission must be separate expressions of intent.

Mistake 3: hiding the privacy notice or burying it in a link

Landing pages:

• Very small print
• Links not visible under Checkbox
• Vague wording such as I have read and accept

According to Board decisions, these methods do not fulfil the duty to provide information.

Mistake 4: obtaining multiple permissions with one checkbox

Example incorrect application:

By joining the campaign, I confirm I have read the KVKK privacy notice,
and I agree to receive commercial electronic messages.

This structure is invalid in terms of both KVKK and ETK.

3. Correct data processing steps for promotions and prize draws Step 1: create a purpose-based data inventory

The following questions should be asked for each campaign:

• What is the main purpose of this campaign?
• What data is required to accomplish this goal?
• Which data would be nice to have but is legally unnecessary?

Step 2: distinguish legal bases

Activity — legal basis
Prize draw entry — entering into a contract
Announcement of winners — legitimate interest
Email/SMS campaign — explicit consent
Analytics and tracking — explicit consent / Consent Mode

Step 3: Prepare the privacy notice for the campaign

The "General KVKK text" is not enough for end-of-year campaigns.
privacy notice must necessarily include the following headings:

• Specific purpose of the prize draw or promotion
• Categories of data collected
• Storage periods
• Third parties receiving data
• Data subject rights

4. KVKK Checklist on Campaign Landing Pages and Forms

• Is the privacy notice visible and accessible?
• Are the required fields genuinely necessary?
• Is marketing permission optional?
• Are the consent checkboxes separated?
• Does the cookie banner work?
• Is the form logs being recorded?

One of the most frequently requested records in KVKK audits is: How was consent obtained and stored during this campaign? 5. Data retention and deletion after the prize draw

The biggest mistake after a prize draw ends is indefinite retention of data.

The correct approach:

• Winners’ data → retain for statutory periods
• Non-winning participants → delete within a short period
• People without marketing permission → delete immediately

Deletion and anonymisation must be recorded.

6. End of Year KVKK Compliance Protocol for Marketing Teams

• Run a KVKK check before launching the campaign
• Joint approval with the legal or compliance team
• Custom privacy notice for each campaign
• Log consent records
• Data erasure calendar at end of campaign
• Analyse the roles of agencies and suppliers

As of year-end 2025, marketing activities are classified as a high-priority risk area in KVKK audits. 7. How does B10 Digital support marketing KVKK compliance?

B10 Digital offers a KVKK approach tailored to marketing teams:

• Campaign-based KVKK risk analysis
• Landing page and form audits
• Legal design of prize draws and promotions
• Consent Mode v2 integration
• Creation of consent and log evidence sets
• Agency and platform role-compliance analysis

This enables marketing teams to achieve legal security without compromising campaign speed.

KVKK Compliance Consultancy for End of Year Campaigns