Turkish Personal Data Protection Authority's Guideline On The Considerations For The Processing Of Biometric Data

The Turkish Personal Data Protection Authority ("Authority") has published The Guideline on the Considerations for the Processing of Biometric Data ("Biometric Data Guide") on its official website on September 16, presenting the Authority's guidance on data controllers' biometric data processing activities.

Below, you may find our evaluations regarding the recommendations within the Biometric Data Guide, the measures specified to fulfill them, sanctions that may arise in case of non-compliance, along with the comparisons with the EU acquis.

i. What is Biometric Data?

Pursuant to the Article 6 of the Law on the Protection of Personal Data Numbered 6698 ("Law"), biometric data is defined as one of the "special categories of personal data"¹ and may be processed subject to stricter rules than other types of personal data. According to Article 6 of the Law, processing of biometric data is prohibited unless the data subject has given his/her explicit consent, or