Table of contents
What is the Message Management System (İYS)?
The Message Management System (İleti Yönetim Sistemi, İYS) is a web-based platform, provided by the Union of Chambers and Commodity Exchanges of Türkiye (TOBB) as authorised by the Ministry of Trade, on which commercial electronic message permissions and complaint processes can be managed, within the framework of Law No. 6563 on the Regulation of Electronic Commerce (6563 sayılı Elektronik Ticaretin Düzenlenmesi Hakkında Kanun), which entered into force on 1 May 2015, and the Regulation on Commercial Communication and Commercial Electronic Messages (Ticari İletişim ve Ticari Elektronik İletiler Hakkında Yönetmelik). The Message Management System is a national database system with security standards that enables service providers to store and manage the consents they obtain from recipients in order to send commercial electronic messages by call, SMS and email, and enables recipients to exercise their right to consent and refuse and to submit and manage complaints about commercial electronic messages. For details: https://iys.org.tr/iys/nedir
Who is a service provider?
A Service Provider is any natural or legal person who sends messages containing data, voice or images for commercial purposes in the electronic environment using means such as telephone, call centres, automated dialling machines, smart voice recording systems, email and short message services.
Who is a recipient?
A recipient is a person who receives commercial electronic messages. Recipients can manage their permissions from a single account, change their permission status quickly and easily, and file complaints.
Who is a business partner?
İYS Business Partners (integrators) are companies that obtain an API licence and access to the live environment from İYS and enable their own customers to use İYS services.
What is a commercial electronic message?
Any commercial communication made by natural and legal persons through electronic communication tools, in the course of their commercial activities, in order to promote or market their goods and services or to increase the recognition of their business, is called a commercial electronic message.
Commercial electronic messages within the scope of İYS that require consent
- Any commercial communication made by natural and legal persons through electronic communication tools, in the course of their commercial activities, to promote or market their goods and services or to increase the recognition of their business, - Commercial electronic communications intended to increase the recognition of businesses, such as celebrations, congratulations or good wishes, - Satisfaction surveys.
Commercial electronic messages outside the scope of İYS that do not require consent
Prior consent is not required for messages containing notifications about an ongoing subscription, membership or partnership, collections, debt reminders, information updates, purchases and deliveries or similar matters, or in cases where the relevant legislation imposes an obligation on the Service Provider to provide information.
What is a merchant or tradesperson?
A merchant is a recipient classified as a merchant or tradesperson under the legislation. A contact address can be registered in İYS both as an individual and as a merchant. Prior consent is not required for commercial electronic messages sent to the electronic contact addresses of recipients who are merchants or tradespeople. However, because merchant and tradesperson recipients have the right to refuse, these permissions must also be transferred to İYS.
Important
Under the Regulation, consents not transferred to the Message Management System by 31 December 2020 for service providers with 150,000 or more message consents, and by 31 May 2021 for service providers with 150,000 or fewer commercial electronic message consents, became invalid.
Transition timeline (2020–2021)
- January 2020 — Launch of İYS and informing service providers and citizens - January 2020 — Opening of İYS applications for service providers - July 2020 — Opening of the İYS platform for service providers - 1 December 2020 — Final data upload date to İYS for service providers with 150,000 or more message consents - 15 February 2021 — Back-dated permissions accepted as consented for service providers with more than 150,000 contact addresses - 31 May 2021 — Final data upload date to İYS for service providers with 150,000 or fewer message consents - 15 July 2021 — Back-dated permissions accepted as consented for service providers with more than 150,000 contact addresses
How do KUTBU and the Message Management System work together?
KUTBU cooperates with the Message Management System. As a result, for our users who became users by 30 November 2020 and whose member permissions are stored on KUTBU systems, once they register with İYS and send us their registration details, we upload your current permission data to İYS on your behalf.
What KUTBU users need to do
If you are already a KUTBU user, you must register with the Message Management System using your company’s e-signature. Once you inform us after registering, we will transfer the permission data stored in your existing accounts to İYS on your behalf. If any of the mandatory fields required by İYS are incomplete during the transfer, we will contact you to complete the information.
What new KUTBU users need to do
To send SMS and email with our products, you must first register with the Message Management System. For details: https://iys.org.tr/hizmet-saglayici/basvuru/nasil-yapilir
Is İYS registration mandatory?
Yes. To continue the notification services you carry out online, such as campaigns, announcements and promotions, you must complete your İYS registration. Each service provider registered with İYS, and each of its brands, will be assigned its own unique İYS number.
Can I use your services without registering with İYS?
No. To use the email sending service, unless you are an institution or organisation outside the scope of İYS, you must register with İYS and complete its requirements.
What documents are required to apply to İYS?
Only persons who have a MERSİS (Central Registry Record System) record and appear as authorised according to that record can apply, using their e-signature. For details: https://iys.org.tr/hizmet-saglayici/basvuru/nasil-yapilir
What details should the permissions uploaded to İYS contain?
- Contact address - Permission type (consent/refusal) - Permission date - Preferred communication channel (call, SMS, email) - Permission source (the recipient providing their electronic contact address for transactions concerning the supply of goods and services before 1 May 2015, a wet-signed consent form, a website, etc.)
How can I obtain consent to send messages?
Consent to send messages can be obtained in 3 ways. - Physically: by signing a form or survey, or at events such as trade fairs - Electronically: via a website, mobile app, short message, call centre or social media tool - Through İYS: via the İYS website, İYS mobile, the İYS call centre or the İYS SMS channel
How is consent obtained through İYS?
Once the Message Management System is operational, you can obtain consent using the consent services it will offer via its call centre, short message number and short link.
What are the proof of consent obligations?
According to the Regulation on Commercial Communication and Commercial Electronic Messages dated 4 January 2020: for consents not obtained through İYS, the burden of proving that consent was obtained lies with the service provider. Consents not obtained through İYS are registered in İYS by the service provider within three business days. Consents not registered in İYS are deemed invalid.
How will I track the consent or refusal notifications I receive?
Consent and refusal notifications for our users will be managed by us and forwarded to our users.
Is consent required for every message sent?
No. Under the law, there is no requirement to obtain consent before sending messages concerning an ongoing subscription, membership or partnership, collections, debt notifications, information updates, sales and deliveries, and similar processes.
I have two different companies. Is consent obtained for one company valid for my other company?
No. İYS applies a consent process based on trade name. A separate consent process will therefore be required for each of your companies.
How will İYS processes work for companies doing B2B business?
There is no issue with companies you do B2B business with, since you have a business relationship with them. However, if you market to these companies, you must notify İYS of the permissions you use for every marketing email. Apart from informational or transactional emails, if any email is sent for commercial or marketing purposes or to promote a product, the permissions of the target audience must be registered in İYS.
Are notifications about purchased products, such as licence or purchase notifications, within the scope of İYS?
No. Notifications about purchased products are not within the scope of İYS. Since these are not messages that depend on permission, they are considered outside İYS.
How do the Message Management System (İYS), business partners (integrators) and intermediary service providers distinguish informational from commercial messages?
It is the service provider’s responsibility to determine whether an electronic message is a commercial message or an informational message. Within the scope of this responsibility, the service provider notifies the relevant intermediary service provider from which it receives the message sending service.
Does every service provider have to work with business partners (integrators)?
Service providers with fewer than 250,000 contact addresses can access İYS messaging services only through the business partners (integrators) they authorise. Service providers with fewer than 250,000 contact addresses cannot transfer their permission data directly to İYS themselves. Service providers with more than 250,000 contact addresses may, if they wish, access İYS messaging services through business partners (integrators), or they may transfer data to İYS themselves and keep it up to date. In that case, when sending messages we rely on the information you provide to us. In this model, the responsibility for synchronising with İYS and providing up-to-date data lies with your company.
What is the scope of KUTBU’s service?
As KUTBU, we provide services for email. For other services such as SMS and call centres, you need to work with a different integrator, or have the data transferred through your own integration or your existing business partner. İYS has no limit here; you can use and work with more than one integrator.
How should companies that do not state when they obtained İYS permission proceed?
Whether you transfer data through integrators or transfer your data to İYS yourself, İYS requires the permission date. As KUTBU, we are always responsible to the users of our products, and we will proceed according to your instructions here. If you have the registration dates, you can use them, or you can use the dates on which the data was uploaded to us.
Are newly added users updated in İYS through KUTBU?
Yes. Our services transfer your new memberships to İYS in real time. Within the scope of our service, we keep all data on newly added and unsubscribed users synchronised between İYS and KUTBU services.
Will imported customers be transferred to İYS directly as customers who have given permission?
Data confirmed as permitted in our systems will be transferred. Data whose permission is off will not be transferred to İYS. İYS does not allow data without permission in the initial transfer. We recommend that you check the permission data in our system before the transfer date.
Are users who opt out of İYS flagged on KUTBU?
Yes. Our main goal here is to keep your consented users up to date. The two systems are kept in sync by tracking users’ permission opt-in/opt-out updates. If a user you uploaded to İYS through us turns off their permission and later gives consent again through İYS channels, they are reactivated in your user panel.
I understand that the data shared on İYS may be used. In that case, how will the data privacy required by the KVKK be ensured?
We expect this to be determined by the agreements brands make with İYS. No such authority or model exists within the scope of our work.
Will the last or the first update date of the permission be sent to İYS?
The last update date of the permission will be sent. After that, we will inform İYS of every update. What İYS pays most attention to is the time and date the permission was obtained; in effect, service providers are asked for a timestamp. İYS uses the latest date and time at which the permission was obtained.
A phone number may be registered for more than one user. How should we proceed in that case?
We send email addresses, SMS numbers and phone numbers to İYS without linking them to any ID. İYS does not expect us to match users with phone numbers. Each phone number will be sent separately together with its brand-based permission. There is no obligation to use an integrator to transfer data to İYS; you need to connect to İYS as an integrator and handle the flow of permission information. In that case, when sending messages we will rely on the information you provide to us. In this model, the responsibility for synchronising with İYS and providing up-to-date data lies with your company.
I heard that İYS has not shared its APIs. Is that true?
The APIs and the necessary documentation have been shared. Our work on the system integration is continuing intensively.
If we do not carry out marketing communication, we do not need to comply with İYS. Is that correct?
İYS expects only companies that carry out marketing communication to transfer their data to the İYS system. For detailed information on this subject, you can check https://iys.org.tr/. Registering with the İYS system is entirely the company’s choice. However, note that if you hold permission-based data and do not register and transfer the data within the expected period, you will not be able to use that data for marketing after the final upload date.
Until the integration is completed, is there a manual upload limit by number of people or size?
Different email packages are offered to you. However, there is no definitive information about a manual upload limit; you will be informed according to your package.
Do we need permission from İYS for push notifications?
No, push notifications fall outside the scope of İYS.
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