Guideline On The Processing Of T.R. Identity Numbers Published By The Personal Data Protection Authority

Within the scope of the Law No. 6698 on the Protection of Personal Data ("Law"), the Turkish Republic Identity Number ("T.R. ID Number") information of individuals is not included in the category of sensitive personal data, but rather is evaluated within the scope of identity data in the general category of personal data. However, in practice, the direct processing of the T.R. Identity Number data while the same data processing purpose could be achieved by processing different data has been subject to criticism due to the fact that the T.R. ID Number is a type of data that can provide access to other personal data of the data subject.

It is without doubt that the processing of T.R. ID Numbers should be approached with particular sensitivity. Indeed, the Personal Data Protection Board ("Board"), in a recent decision¹ on the processing of the T.R. ID Number in the mobile application of the data controller who provides meal card services, evaluated that although the