On 16 December 2020, Turkey's Personal Data Protection
Authority (the "Authority") announced
(the "Announcement") on its website regulations
applicable to public disclosure of personal data by data
processors.
The Announcement provides, in relevant part, as follows:
Articles 5 and 6 of the Personal Data Protection Law number 6698
(the "Law") regulate the handling of
personal data by data processors (as that term is defined by
applicable law). Article 5 in particular provides, inter
alia, that public disclosure of an individual's personal
data may be accomplished lawfully only by that same individual.
Article 5 incorporates the notion of intention; so that public
disclosure by a data processor of an individual's personal
data, whether accidentally, inadvertently, or otherwise, absent the
intention of that individual to make the data public is unlawful
under Article 5.