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.
