This Memorandum has been prepared to provide information on the
legal framework of the Law numbered 6698 on Protection of Personal
Data ("Law") which has been published in
the Official Gazette dated April 7, 2016 and numbered 29677 and to
evaluate the procedures to be followed by companies to be in
compliance with the Law from the point of view of employment law
and contractual law.
I. The Definitions Introduced by the Law on Protection of
Personal Data
Under Article 3 of the Law, "personal data" is defined
as any type of information of any real person whose identity is
determined or may be determined. In this regard, defined real
persons may appear as employees, business partners, clients, etc.
"Data Controller" is also defined in the same Article as
real or legal persons that determine the purposes and vehicles of
data processing and that are responsible for the establishment and
management of the data registration system. Accordingly, as of the
effective date
