The Main Causes of KVKK Breaches on Municipal Websites

⏱️ Reading time: 10 min · 📁 Category: KVKK, Municipal Web Sites & Digital Services

The Main Causes of KVKK Breaches on Municipal Websites

Municipal websites bring together services such as applications, complaints, requests, payments, appointments and information,
offering numerous digital services in one place.
This extensive functionality turns municipalities into
high-risk digital data processing environments under KVKK.

An examination of the Turkish Personal Data Protection Board’s decisions and on-site audits shows that
a significant proportion of KVKK breaches in municipalities
occur directly through websites.
In this article, we examine
the main structural causes of recurring breaches.

The main problem is:
A website is an active data processing platform, rather than merely an information display. 1. Cookie Banner Design and Misleading Use

One of the most common sources of breaches on municipal websites is
cookie banners designed in violation of the law.
Most municipalities have banners, but these banners
do not obtain legally valid consent.

• Presenting all cookies as "essential"
• Preselected checkboxes
• Statements such as “By continuing, you are deemed to have accepted”
• A hidden or missing rejection option

The Board’s approach:
What matters is that consent is freely given and informed, rather than simply having a banner. 2. Mismatch Between Cookie Policies and Actual Practice

In most municipalities, cookie policies
do not match the tracking technologies actually deployed on the site.

• Failure to specify analytical or third-party cookies
• General statements about cookie duration and purpose
• Scripts and tags running without being listed in the policy

The Board regards this as
a breach of the transparency obligation.

3. Excessive Data Collection in Online Application and Request Forms

Municipalities’ online application, petition and request forms
are among the areas where the data minimisation principle is breached most often.

• Requesting a Turkish national identity number unrelated to the service
• Unnecessary contact information
• Unstandardised free-text fields

The KVKK principle is clear:
Data cannot be collected on the grounds that "it may be needed in the future". 4. Failure to Integrate Privacy Notices into Forms

On many municipal websites, the privacy notice is either missing
or provided only through a redirect to a page entirely separate from the form.

• No privacy information before the form
• Privacy notices that are difficult to access
• The text is not specific to the relevant service

5. Obtaining Explicit Consent in the Wrong Context or Manner

Another common municipal mistake is
requesting explicit consent in online forms when a legal basis already exists.

• Requiring consent as a condition for submitting an application
• Combining consent and acknowledgement of privacy information in one checkbox
• Stopping the service when consent is withdrawn

These practices invalidate consent and
expose the municipality to a higher risk of sanctions.

6. Uncontrolled Use of Third Party Scripts and Services

Map services, video players, analytics tools and
social media plugins are frequently used on municipal websites.

• Scripts running before consent
• Transferring data abroad
• Unclear distinction between data processor and data controller

Municipalities are responsible for all third-party tools on their websites
in their capacity as data controllers. 7. Security and Logging Deficiencies

Application and form data collected on websites
are often inadequately secured.

• Administration panels exposed to unauthorised access
• Lack of encryption
• Failure to retain access and activity logs

Why Are Web-Based Violations Repeated in Municipalities?

• Treating websites as purely technical work
• A disconnect between legal and IT teams
• Using ready-made themes and plugins without scrutiny
• Omitting audits and testing

A website should undergo a KVKK review during design,
rather than after it goes live. What Should Municipalities Do? (Summary)

• Redesign cookie banners to comply with the law
• Minimise the data collected in each form
• Prepare service-specific privacy notices
• Connect third-party scripts to the inventory and consent system
• Strengthen website security and logging mechanisms

Conclusion

Municipal websites are one of the most visible and auditable areas in terms of KVKK.
The main cause of breaches is not technical inadequacy, but
the failure to integrate legal requirements into digital design.

A poorly designed website
becomes a source of recurring breaches for municipalities.

KVKK Compliance Analysis for Municipal Websites