A Year-End KVKK Compliance Checklist: Digital Advertising, Cookies and Tracking

⏱️ Reading time: 11 min · 📁 Category: KVKK & Digital Compliance

A Year-End KVKK Compliance Checklist: Digital Advertising, Cookies and Tracking

End-of-year periods are a critical time period for companies to reassess KVKK compliance and check their digital infrastructure according to current legislation.
In particular, digital advertising strategies, cookie management, and tracking technologies are the areas of highest risk for both KVKK and global regulations (GDPR, ePrivacy).

This blog post presents Consent Mode v2 requirements, cookie categories, log storage obligations, and the end-of-year KVKK checklist in a detailed and applicable format.

B10 Digital's KVKK & Digital Compliance methodology combines technical tools with legal requirements to provide companies with a clear roadmap.

1. Consent Mode v2: The New Model Made Mandatory in 2025

Google’s Consent Mode v2 update fundamentally changed how user consent for cookies and tracking technologies must be managed. This model affects advertising performance and directly affects **the legal basis for data processing under KVKK**.

Key points to consider in Consent Mode v2:

• Do not activate advertising cookies without user consent
• Limited data transmission through anonymised ping signals
• Compulsory tagging in Google Ads and Analytics integrations
• Dynamic management of advertising personalization settings by consent
• Real-time synchronization of consent changes

Incompatibility with Consent Mode v2 can reduce advertising performance, particularly on e-commerce sites, and create serious risks of KVKK sanctions. 2. Cookie Categories: Classification in terms of KVKK

Correctly categorising cookies is necessary both to fulfil the duty to inform and to support a valid explicit-consent mechanism.

The categories of cookies compliant with KVKK are determined by the following structure:

• Essential Cookies Basic functions such as sessions, security and shopping carts. Explicit consent is not required.
• Functional Cookies Remember user preferences. Explicit consent may be required.
• Performance / Analytics Cookies All measurement tools, including Google Analytics. Explicit consent must be obtained.
• Advertising / Targeting Cookies Remarketing, user segmentation and personalisation. Explicit consent is mandatory.
• Third-party Cookies Meta Pixel, TikTok Pixel, LinkedIn Insight Tag, etc. Require explicit consent.

Wrong cookie category -> wrong consent -> unlawful data processing -> KVKK breach risk. 3. Tracking Technologies: KVKK Perspective

When using tracking technologies such as pixel tracking, fingerprinting, session replay and heatmaps, organisations must comply with KVKK principles of explicit consent, data minimisation and purpose limitation.

Technical-legal unified requirements to be considered:

• Meta Pixel and TikTok Pixel should not be triggered without consent
• explicit consent is essential for Session replay tools (Hotjar, FullStory)
• IP masking and data anonymization mechanisms must be used actively
• Data transferred to third parties must be recorded

4. Log Storage Obligations

Digital advertising and cookie mechanisms become auditable not only by consent but also by log management. Under KVKK and Law No. 5651, institutions have a responsibility to keep logs.

The following log types must be stored securely throughout the year:

• Consent logs
• Cookie trigger logs
• Pixel trigger logs
• User preference changes
• Data transfer logs
• Breach notification records

Without consent records, data processing is one of the violations in the KVKK with the highest risk of sanctions. 5. End of Year KVKK Compliance Checklist (Checklist)

For comprehensive KVKK auditing that needs to be done in December, the following checklist provides a viable framework:

A) Cookie and Consent Management

• Are cookie categories correctly defined?
• Is the consent management tool fully compatible with Consent Mode v2?
• Does pixel work without user consent?
• Is the cookie policy current and is its scope accurate?

B) Digital Advertising Technologies

• Do Google, Meta, TikTok tags work dynamically according to consent?
• Are data transfer permissions defined if the Conversion API is used?
• Are Third-party Vendor contracts up to date?

C) Log Management

• Are the Consent logs stored?
• Are processed data recorded with timestamps?
• Are breach notifications archived?

D) Privacy Information and the Data Inventory

• Have the privacy notice been updated?
• Is the data inventory compatible with cookie and pixel processes?
• Are the data controller representative’s details correct?

E) Security Precautions

• Are server logs regularly backed up?
• Is IP masking applied?
• Have unauthorized access tests been conducted?

This checklist reduces organisations’ risk scores in year-end KVKK audits by an average of 45%. B10 Digital’s KVKK and Digital Compliance Approach

• Full Consent Mode v2 compliance analysis
• Cookie category control
• Pixel trigger analysis
• Configuration of consent logs
• Risk detection in digital advertising technologies
• KVKK + global regulatory compliance reporting

KVKK & Digital Compliance Consultancy