How Is AI Use Assessed Under KVKK?

⏱️ Reading time: 10 min · 📁 Category: KVKK & AI Compliance

How Is AI Use Assessed Under KVKK? (2026 Guide)

KVKK compliance in AI directly concerns how AI systems collect, process and analyse personal data
and use it in decision-making. Today, many companies use AI for customer analysis, recommendation systems,
automation and decision support. However, this use creates serious legal
responsibilities under KVKK.

The basic rule is clear: AI use is not exempt from KVKK.
AI is only a tool; however, all data processed through it is subject to KVKK provisions.

Short answer: AI use complies with KVKK, provided the processing purpose is determined,
a legal basis is established, and data minimisation and transparency are ensured. Does AI process personal data under KVKK?

Yes. AI systems commonly work with personal data such as user behaviour, transaction history, preferences,
text and images.
AI applications are therefore directly engaged in personal data processing.

In particular, risk is higher in the following areas:

• Customer segmentation
• Profiling
• Automatic decision-making systems
• Chatbot and customer service
• Image and audio processing systems

Key KVKK risks when using AI 1. Using data beyond its intended purpose

AI systems tend to use data beyond the purpose originally defined.
This conflicts with KVKK’s purpose limitation principle.

2. Excessive data collection

The use of excess data violates the principle of data minimization.

3. Lack of transparency

Users often do not know how their data is processed.
This can lead to a breach of duty to inform.

4. Risks of automated decision making

AI systems can make automated decisions about users.
If these decisions have a legal impact, they should be evaluated separately under the KVKK.

5. Data security issues

If the security of data sets used in AI systems is not ensured,
there is a risk of data leakage.

B10 insight: AI risk begins not in the algorithm, but in
data management. How can AI use be made compliant with KVKK?

The following steps must be taken to make AI systems compliant with KVKK:

The purpose of data processing must be clearly determined

Clearly define the purpose for which AI is being used.

The legal basis must be established

Identify a legal basis, such as explicit consent, a contract or legitimate interest.

Data minimization must be implemented

The system should only work with necessary data.

Provide the required privacy information

It should be made clear to the user that the data is processed in artificial intelligence systems.

Prefer anonymisation

Where possible, anonymous data should be used instead of personal data.

Risk analysis must be performed

The legal and technical risks that artificial intelligence use can pose should be assessed in advance.

Practical fact: AI systems that use anonymous data
significantly reduce KVKK risks. The relationship between AI and explicit consent

In the use of artificial intelligence, there is not always a need for explicit consent.
However, explicit consent may be required, particularly for
profiling, behavioural analysis and marketing uses.

Therefore, each use scenario should be considered separately.

The most common errors in artificial intelligence use Uploading all data to the system

Unnecessary use of data is a KVKK violation.

Failing to provide privacy information

The user is not informed about the use of artificial intelligence.

Failing to check the data source

The lawfulness of the training data is not assessed.

Failing to monitor automated decisions

AI outputs are not checked.

B10 approach: artificial intelligence = data responsibility

At B10 Digital Agency, we approach AI projects not only as technology, but from the perspective of
data responsibility.
We structure the process around KVKK compliance, data management,
risk analysis and transparency
.

Because when the right structure is not established, AI becomes a serious legal risk, not an advantage.

Conclusion

The use of artificial intelligence can be carried out in accordance with the KVKK.
This requires correctly structured data processing activities.

Otherwise, AI systems may cause KVKK violations that go unnoticed.

Let’s make your AI processes compliant with KVKK