1. What changed due to COVID-19?The Data
Protection Law still applies to personal data processing activities
and data controllers must comply with the general principles of
data privacy, such as fairness and proportionality. Data
controllers must still have legal grounds for processing personal
data based on the type of data or rely on one of the exceptions
provided in the legislation.In light of the foregoing, data
controllers must bear in mind the general principles of data
privacy and their obligations as data controllers in terms of the
explanations provided below.
Moreover, the Turkish Data Protection Authority has not provided
any guidance on the matter yet; thus, the following evaluations are
based on literal interpretations of the law and approaches from
different jurisdictions, which are explained in the table at the
end of this alert.
