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ARTICLE · 02 FEBRUARY 2022

The Turkish Data Protection Board's New Principle Decision On Blacklisting Practices And The Concept Of Joint Controllers

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On 20 January 2022, the Turkish Data Protection Authority ("Authority") published a principal decision ("Decision") in the Official Gazette regarding blacklisting practices in the car rental industry.

TurkeyPrivacy
Kemal Altug Ozgun
Kemal Altug Ozgun
Ece Mert
Ece Mert
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On 20 January 2022, the Turkish Data Protection Authority ("Authority") published a principal decision ("Decision") in the Official Gazette regarding blacklisting practices in the car rental industry. The Decision introduced the concept of the joint controller by defining that both car rental companies and car rental software companies function as data controllers in blacklisting practices.

How Does the Blacklist Practice Work?

In its Decision, the Authority determined that software development companies provide car rental companies with software that allows them to create blacklists containing comprehensive information about natural person customers for use in future rentals. According to the Decision, these blacklists include records such as accidents, damage to the vehicle, and payment problems during the use of the vehicle.

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