KVKK Board recognized the "right to be forgotten" with its 2020 decision. Process: Removal form (RTBF) to Google → Complaint to the KVKK Board if Google refuses → Forced removal by Board decision. Court action (KVKK article 14 compensation) is parallel.
Which content can be removed?
- Past accusation / indictment (especially after acquittal / decision not to prosecute).
- Old bankruptcy, declaration of enforcement (10 years + if paid).
- Old personal illness, disease information (health data - special quality).
- Social media post made at a young age (if harmful to the person).
- Document disclosure in the former employment relationship (after the end of the contract).
Google RTBF form
From support.google.com/legal/contact/lr_eudpa:
According to Google's own jurisprudence: the acceptance rate for journalists, public officials, and advanced criminal organizations is low; high for private individuals and old indictments.
KVKK Board application
If Google refuses, written complaint to the KVKK Board within 30 days:
- Client communication.
- Screenshot of Google form rejection.
- Legal justification: KVKK art.11, art.7 (deletion/destruction), art.14 compensation.
- Public interest vs private life debate.
The board's decision generally takes 3-6 months; There is the authority to impose administrative fines + forced removal.
It was erased from the criminal record, but it's still on Google. What to do?
This is the classic case of the right to be forgotten. Google form is filled with criminal record decision + file number + date; If rejected, it goes to the Board. The decision of the Supreme Court of Appeals HGK 2020/467 is in this direction.
Content appearing in foreign media?
GDPR Art. 17 (right to erasure) Same method for intra-European sites. On US-based sites, the Google US RTBF form is more limited; However, application with KVKK + GDPR is mandatory on its website (for operators with an annual turnover of over 250,000 EUR).
I was acquitted but the news does not change, is the newspaper responsible?
Yes. You have the right to apply directly to the newspaper under KVKK article 11; If the newspaper objects, a complaint may be filed to the Board or a lawsuit for financial compensation may be filed against the press.
Block single URL or category?
RTBF is evaluated separately for each URL; Google does not block "all results". A separate form is required for each URL in the active application.
How long does the process take?
Google: 7-30 days. Board: 3-6 months. Court action: 6-18 months; However, interim measures may be taken from the court for the client who is waiting for the Board process.
Relevant legislation
- Law No. 5651 Article 9 — Violation of personal rights; URL based access block.
- Law No. 5651 art.9/A — Privacy of private life; Action within 24 hours.
- KVKK no. 6698 article 11 — The right to be forgotten; search engine results.
- TCK art.134-136 — Violation of privacy, video/audio recordings.
- FSEK art.71 — Measures and removal of content in case of copyright infringement.