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ARTICLE · 25 JANUARY 2022

The Concept Of "Joint Controller" Is Now Defined In Turkish Data Protection Law

Gen Temizer Erdogan Girgin Attorney Partnership
Gen Temizer Erdogan Girgin Attorney Partnership
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On 20 January 2022, the Turkish Personal Data Protection Authority ("Authority") issued a principal decision ("Decision") in the Official Gazette on the practice of blacklisting customers in the car leasing sector.

TurkeyPrivacy

On 20 January 2022, the Turkish Personal Data Protection Authority ("Authority") issued a principal decision ("Decision") in the Official Gazette on the practice of blacklisting customers in the car leasing sector. In the Decision, the Authority evaluates the software used by car leasing companies for blacklisting practices and concludes that:

  1. the software company and the car leasing companies are joint controllers;
  2. the profiling of customers through the mentioned blacklist and data transfer between other car leasing companies (we provide details below) constitute a violation of Turkey's Personal Data Protection Law ("DP Law") and therefore the data processing activities in question must be ceased; and

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