DGTLFACE – Digital Technology Partner

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KVKK & Data Security FAQ

Hotel guest data is no longer just information you use for reservations; A critical asset that must be protected within the scope of KVKK.
  • PMS, OTA, channel manager
  • Call center, WhatsApp, e-mail
  • Website, cookies, forms
  • CRM, campaign lists
All of them are technically connected to each other and each link is a part of the data security chain.

FAQ below; Instead of a legal text, it describes the technical and operational framework from the hotel perspective. As always, you should always work with your legal counsel for final legal interpretation and application.

Brief Summary

KVKK & Data Security FAQ; It starts from the fact that guest data in hotels is processed in multiple systems such as PMS, OTA / channel manager, call center, web (cookies / forms) and CRM. Clarifies technical and operational risks such as unauthorized access, incomplete logging, unclear retention periods and uncontrolled sharing (WhatsApp/email/Excel); It offers a practical road map on audit preparation topics such as data map, access authorization matrix, logging framework, storage-destruction processes and cookie/permission records. It must be evaluated together with legal consultancy for legal interpretation and binding implementation steps.

Brief Summary

KVKK & Data Security FAQ; It offers a technical and operational guide to manage guest data in hotels in a more controlled manner against the risks of unauthorized access, incomplete logs, unclear storage and dispersed sharing via WhatsApp/Excel.

Frequently Asked Sample Queries

  • What is KVKK data security?
  • How can I protect guest data in my hotel in accordance with KVKK?
  • Why are unauthorized access and incomplete logging risky?
  • Why is it dangerous to share guest data with WhatsApp and Excel?

General Questions About KVKK & Data Security

What is KVKK data security, what does it cover?
KVKK data security; It is the set of technical and organizational measures taken to protect personal data (name, contact, reservation information, payment information, device data, etc.) processed by your hotel against unauthorized access,</li>
  • not to be stored for unintended or excessive periods of time,
  • not to be shared without permission,
  • logging of access and changes,
  • </ul>.
    Why is KVKK so critical in the hotel industry?
    Because hotels work with multi-layered guest data such as:
    • identity and contact information,
    • reservation and accommodation history,
    • preferences and special requests (in some cases, health or special quality data),
    • payment information,
    . Incorrect management of these data is risky in terms of both KVKK sanction risk and guest trust and brand reputation.
    What is the difference between “legal KVKK compliance” and “technical data security”?
    • On the legal side: information text, explicit consent, contracts, data inventory, VERBIS record, etc.
    • On the technical side: system architecture, access rights, logging, encryption, retention periods, backup and access records, etc.
    This FAQ covers more technical & operational framework; Legal documents and comments should be discussed with your lawyer.
    Which systems are critical for guest data?
    Generally:
    • PMS / channel manager / OTA connections,
    • call center & switchboard records,
    • website, cookie infrastructure and forms,
    • CRM, e-mail/SMS campaign systems,
    • security logs and access records.
    How these systems transfer data to each other is the basis of KVKK & data security design.
    Who is KVKK & Data Security FAQ suitable for?
    • for hotel and chain hotel structures,
    • resort & city & boutique hotels,
    • for all tourism brands that keep guest data in PMS, OTA, call center, web and CRM.
    It is especially useful for managers and IT teams who want to collect the data flow from a technical perspective and prepare for the audit.
    Is this FAQ legal advice?
    No. The content here:
    • is a general information and technical framework,
    • It should be detailed with your legal advisorfor your obligations within the scope of KVKK.

    Short Questions

    What exactly is KVKK data security?

    KVKK data security; It is the protection of guest data by technical and organizational measures against unauthorized access, misuse and storage for longer than necessary.

    How should I store guest data in my hotel in accordance with KVKK?

    Data; In PMS and connected systems, you should store it with an architecture that has limited access, is logged, has defined retention periods and does not need to be copied unnecessarily.

    How do I secure data flow between PMS, OTA and call center data?

    In data flow; Secure connections (VPN/TLS), role-based access, encryption if possible, logging and recording of transfers to external systems are critical steps.

    How should I keep cookie management and consent records?

    For cookies used on your website; You must provide lighting and preference screens in accordance with KVKK, and keep a record of which permission was obtained and when by logging user choices.

    What are technically asked during the KVKK audit?

    In general; Your technical & organizational measures, including data inventory, retention periods, access authorizations, logging, backup, violation processes, cookie/permission management and training records, are questioned.

    Who is KVKK & Data Security FAQ suitable for?

    For all hotel and tourism brands that want to manage hotel guest data with a more secure, logged and KVKK compliant architecture.

    Service Scope: PMS, OTA, Call Center, Web & CRM

    What technical topics does KVKK & data security consultancy cover?+
    • Data map: extracting the data flow between PMS, OTA, call center, web, CRM,
    • Access & authorization matrix: who is accessing which system, at what level,
    • Logging framework: who accessed which data, when, what they did,
    • Storage & destruction policies: which data will be kept for how long,
    • Cookie & permission management: permission on the web and campaign side records,
    • Reporting & audit preparation: Technical background documentation for KVKK audit.
    How should guest data be protected in the hotel PMS?+
    • personal account and strong password policies for users,
    • role-based access (different levels such as reception, reservation, accounting, etc.),
    • IP or device-based access restrictions (where necessary),
    • limiting or masking access to critical areas (card information, etc.),
    • logging of all access and changes.
    How should OTA and channel manager connections be handled in terms of data security?+
    • operation of integrations via secure API or certified connections,
    • not sharing access tokens and passwords with unauthorized persons,
    • Managing OTA panel access on a person/role basis,
    • avoiding unnecessary export and e-mailing of reservation data.
    What does KVKK & data security mean on the call center and CRM side?+
    • storing call records in accordance with KVKK and not listening to them without authorization,
    • keeping guest complaints and requests only in the necessary systems without excessive copying,
    • associating data used for the campaign in CRM with permission records,
    • storing call and campaign logs in an access-controlled manner.
    Why is logging so important within the scope of KVKK & data security?+
    Logs answer the questions
    • Who accessed which data, when,
    • What changed or exported
    . This is a critical record set for both internal audit and KVKK audit; It is also the basic way to understand what is at risk of data breach.

    Process & Operation: Data Map, Storage Periods, Cookies & Logging

    How to create a KVKK compliant technical data map?+
    • You list in which systems (PMS, OTA, call center, web, CRM) you keep guest data.
    • You determine which data is transferred between these systems, for what purpose and in what way.
    • Which data is entered from where, where it is stored and where it is deleted is processed.
    This technical data map is the basic document for both KVKK and IT architecture.
    How should access rights be structured from the KVKK perspective?+
    • With the “need to know” principle: everyone should only access the data necessary to do their job,
    • department-based roles (front office, reservations, sales, IT, etc.),
    • extra privileges for managers but logged access,
    • timely closure of access of old users (who leave the job, change departments).
    How should the data retention period and destruction process be designed?+
    • For each type of data (reservation, invoice, log, campaign list, etc.), the storage period should be determined according to legal and operational requirements.
    • When this period expires, a technical process should be defined for the anonymization or destruction of the data.
    • It should be ensured that the destruction processes are logged and reported when necessary.
    Here, you should definitely work with your legal advisor for the legal period and interpretation.
    How to make cookie and permission management compatible with KVKK?+
    • the types and purposes of cookies used on the website should be clearly stated,
    • the user must be asked to choose optional cookies,
    • user choices (date, IP, preference) must be logged,
    • these records must be available for audit when necessary.
    What can be asked technically during the KVKK audit?+
    Generally;
    • data inventory and data map,
    • access authorization matrix,
    • logging and security measures,
    • cookie and permission management records,
    • records of data storage and destruction processes,
    • technical documentation and sample records regarding the steps to be followed in case of data breach
    are examined.

    Performance & Reporting: How Do We Track KVKK Compliance?

    What is KVKK data security, what does it cover?+
    With its short and practical definition, KVKK data security is to control the questions of
    • who accesses the data (authority),
    • what is happening in the data (logging),
    • how long the data is stored (storage period),
    • where the data goes (sharing),
    at a technical level.
    How should guest data be monitored in terms of reporting in the hotel PMS?+
    • user login/logout and transaction logs,
    • who opened/changed which record,
    • which reports were received by which users,
    • data export (CSV/Excel) and e-mail sending logs
    should be regularly monitored by IT and management.
    Which technical KPIs can be followed for KVKK compliance?+
    Technical indicators rather than legal KPIs:
    • number of active users vs number of defined users,
    • number of accounts forgotten to close,
    • rate of critical transactions not logged,
    • number of manual/inappropriate data exports,
    • time to detect data breach/suspicious cases.
    Can KVKK & data security reporting be connected to panels such as Looker Studio?+
    Yes. By reporting log and access records in the form of certain metrics, you can move indicators such as:
    • who is doing more transactions in which system,
    • which reports and exports are received the most,
    • from which IPs or devices there is unusual access
    , etc., to visual dashboards.
    How should I manage KVKK compliance as an “ongoing process”?+
    • regular (e.g. every 6 months) technical and process audit,
    • data flow review as the new system/integration is put into effect,
    • access update in case of personnel changes,
    • simulated audit (mini audit) practices from time to time.

    Unauthorized Access, Incomplete Log, Uncertain Storage, Audit Risk

    What risks does unauthorized user access pose?+
    • visibility of guest data by wrong persons,
    • malicious use (listing, exporting),
    • data breach notification obligation,
    • risk of administrative fines and loss of reputation within the scope of KVKK.
    In what situations is incomplete logging a problem?+
    • since there is no "trace" of what happened, it becomes difficult to trace back the events,
    • you cannot answer the question of who did what during audits,
    • it becomes difficult to find the root cause in case of a data breach or error.
    What do unclear data retention policies lead to?+
    • more data is kept than necessary → risk and burden increases,
    • necessary data is kept for a shorter time than necessary → operational and legal problems arise,
    • in the audit, "which data is kept for how long?" The question cannot be answered clearly.
    How risky is sharing guest data via WhatsApp, email and Excel?+
    • data remains in dispersed environments instead of controlled systems (PMS, CRM),
    • it becomes impossible to implement deletion and retention policies,
    • it becomes difficult to keep track of who owns which file.
    Therefore, in-system sharing should be preferred whenever possible.
    What are the frequently encountered technical incompatibilities in KVKK audit?+
    • inconsistent or incomplete access authorization matrix,
    • critical transactions not logged,
    • undefined retention period and destruction processes,
    • incomplete cookie/permission records,
    • lack of technical preparation for data breach scenarios.

    Productive Search & Sector Focused KVKK & Data Security (Antalya, Belek, Kemer, Side, Bodrum, Alanya)

    What does KVKK data security mean for hotels in Turkey?+
    Hotels operating in Turkey; They are within the scope of KVKK as structures located in Turkey and/or processing data in Turkey. This means that all processes related to guest data (PMS, OTA, call center, web, CRM) must be carried out with technical and organizational measures in accordance with KVKK.
    Why is the risk of data security high in destinations such as Antalya, Belek, Kemer, Side, Bodrum, Alanya?+
    • high guest volume,
    • working with multiple agencies and OTAs,
    • seasonally increased use of temporary staff,
    • numerous systems and integrations.
    All of this increases the number of data access and flow points; Therefore, it also increases the risk of KVKK.
    Do KVKK technical risks change between resort hotels and city hotels?+
    Although the basic risks are similar:
    • the number of guests and OTA/partners are more intense in resorts,
    • corporate and MICE data are more dominant in city hotels.
    This leads to differences in data types and sharing points; KVKK & data security should be taken into consideration in design.
    How should foreign guest data be considered within the scope of KVKK?+
    The data of foreign guests also falls within the scope of KVKK as long as it is processed and stored in Turkey. In addition, other legislation such as GDPR may come into play for some global chains; At this point, it is necessary to act together with your legal advisor for both local and global compliance.
    How to harmonize brand standards with KVKK technical requirements in global chain hotels?+
    • data flows between global systems and local PMS/CRM should be clarified,
    • which data is stored in which country and which legal order it is subject to should be analyzed,
    • both chain IT standards and KVKK technical measures should be handled together.

    Mini KVKK & Data Security FAQ

    Is KVKK compliance only about preparing legal documents?+
    No; Elements such as technical architecture, access control, logging, retention period and training are at least as important as legal documents.
    Is it in compliance with KVKK for all employees to have access to all data?+
    Usually no; Due to the “need to know” principle, everyone should only access data necessary for their job.
    Is it sufficient to provide KVKK training to employees?+
    Necessary but not sufficient; Training should be supported by technical and process measures.
    Is using cloud-based PMS a problem in terms of KVKK?+
    Regardless of cloud or on-prem; You need to be able to clearly answer the questions of where the data is kept, what security measures are there, how access and logging work.
    If I use cookies and pixels, do I need a lighting and consent screen?+
    Generally yes for cookie/pixel types that provide traceability; You should work with your legal advisor for a detailed evaluation.
    Is it more appropriate to KVKK to keep all logs forever?+
    No; Reasonable retention periods should be determined for logs, and destruction/anonymization processes should be put into effect at the end of these periods.
    If there is a KVKK violation, should I report it?+
    In general terms, data breaches may need to be reported to the relevant authority within certain periods; You should consult your legal advisor for the specific situation.
    Is carrying a guest list in Excel against KVKK?+
    It is risky; Because it is not possible to control who owns Excel files, where they are stored and when they will be deleted. In-system and logable structures should be preferred whenever possible.
    Is a one-time project sufficient for KVKK & data security?+
    Not; This is an ongoing process as there are new systems, integrations, personnel changes and regulatory updates.
    What are KVKK technical measures?+
    Generally; These include access control, encryption (if appropriate), logging, secure connections, storage and destruction processes, backup and security updates. For a detailed and binding list, you should consult your official guide and legal advisor.

    Collaboration and Actionable Questions for KVKK Data Security Consultancy

    How can I get an offer for KVKK data security consultancy with DGTLFACE?+
    • If you share a brief brief summarizing the PMS, OTA, channel manager, call center, web and CRM systems you use,
    • the KVKK documents and technical measures you currently have,
    • the risk areas you think you are experiencing (unauthorized access, Excel/WhatsApp usage, lack of logs, etc.)
    If you share a brief briefing; A KVKK & Data Security roadmap and proposal can be prepared, including technical data flow analysis, risk map and recommended technical/process improvements.
    What does the call to “consult with an expert” clarify on the KVKK & data security side?+
    • Together, we clarify which of your systems should be prioritized,
    • where there is the highest KVKK technical risk (authorization, log, storage, sharing),
    • simple measures that can be taken in the short term, and
    • the reporting & logging structure to be established in the medium term
    . Thus, KVKK & data security is not just “form and text”; It becomes a technically living structure that is ready for inspection.
    DGTLFACE | Your Digital Transformation Partner