Audio Recording Practices In Businesses: Legal Risks Under Turkish Data Protection Law

1. Introduction

In certain cases, businesses consider expanding the scope of their existing camera systems—used for security and monitoring purposes—to include audio recording in addition to visual recording. However, such practices entail significant legal risks under Turkish Personal Data Protection Law No. 6698 (“Law”).

This article examines the lawfulness of audio recording practices in areas such as reception desks and safes/cash registers within business premises, in light of the Law and relevant case law.

1. Assessment under the Law

Pursuant to Article 4 of the Law, personal data must be processed for specific, explicit, and legitimate purposes, and the data processing activity must be relevant, limited, and proportionate to the purpose for which it is processed. These principles constitute the fundamental criteria for determining the scope of monitoring tools used in workplace surveillance activities.