The concept of personal data protection is based on much older
dates in the European Union countries ('Union' /
'EU') compared to other countries. The reason for this is
that technological developments and the associated danger of data
breach were foreseen early. The underlying reason for this
foresight is the legal awareness and sensitivity to the
technological developments within the Union. In this context,
studies were started in the 1990s with the aim of protecting the
fundamental rights and freedoms of real persons, especially the
right to personal privacy, regarding the processing of personal
data. In line with these studies, on October 24, 1995,
''Directive on the protection of individuals with
regard to the processing of personal data and on the free movement
of such data'' (96/46/EC) was published. Since the
European Union directives will not be applied directly to the all
countries, it was expected that the rules in the Directive will be
transferred to