According to Turkish Personal Data Protection Law No. 6698
("KVKK"), personal data can be defined as any information
relating to an identified or identifiable natural person1. Personal data can be processed with
explicit consent or under the conditions indicated within the scope
of KVKK2. In this sense, it is also
necessary to take into account the situation of employees whose
personal data is seriously processed under KVKK.
Within the scope of employment relation between employee and
employer, by the nature of the Labour Act No:4857
("Labour Act") various personal data of
employee's are processed such as data of first name-surname,
address, wage, criminal record document, medical release, picture,
video footage, every other data of employee's personnel file,
location information of allocated vehicle, recording, mailing, etc.
In this case, the employer often accepted as a "data
controller"3, who determines
the purposes and means of the processing of personal data
