1. OBJECTIVE
This policy is created to establish processes related to the processing and security of Special Personal Data, as defined in Law No. 6698 on the Protection of Personal Data.
2. SCOPE
This policy covers the obligation for data controllers to take "adequate measures" in the processing of special personal data, as stipulated in Article 6, Paragraph 4 of the Law, and the processes related to the processing and security of special personal data according to the decision of the Personal Data Protection Board published in the Official Gazette dated 07.03.2018 and numbered 30353.
3. PRACTICAL PRINCIPLES OF PROCESSING SPECIAL CATEGORY DATA
Article 6 of the Law designates certain personal data as "special category personal data," which, when processed unlawfully, poses a risk of harm or discrimination to individuals.
Special category personal data in the Law includes information about race, ethnicity, political opinion, philosophical belief, religion, sect or other beliefs, dress and clothing, association, foundation or union membership, health, sexual life, criminal conviction, and security measures, as well as biometric and genetic data.
3.1. PROCESSING OF SPECIAL CATEGORY PERSONAL DATA
The processing of personal data designated as "special category" in the Law is conducted by our Company in compliance with the regulations stipulated in the Law. Special category personal data is processed under the following conditions:
Conditions for Processing Special Category Personal Data are outlined below:
Data Type | Condition for Processing | Example |
---|---|---|
Health and personal data related to sexual life | Explicit consent of the data subject | Obtaining explicit consent from the relevant individual for the evaluation of documents such as birth leave, workability/incapability reports, birth reports, and breastfeeding leave applications, as stated in the Labor Law. |
Special category personal data other than health and personal data related to sexual life | Explicit consent of the data subject or stipulated by laws (Tax Laws, Labor Law No. 4857, Turkish Commercial Code) | In accordance with Labor Law No. 4857, an employee's criminal record must be included in their personnel file. |
In our Company, special category personal data of our employees is processed by the unit responsible for Human Resources services. This data includes special category personal data found in the identity documents of individuals with whom our Company has contractual or commercial relationships or their employees/representatives. This data is processed for the following purposes:
The processed data includes, but is not limited to:
This data is recorded and stored by the unit responsible for Human Resources activities.
3.2. ENSURING THE SECURITY OF SPECIAL CATEGORY PERSONAL DATA
Our Company, in its capacity as the data controller for special category personal data, is obliged to take the following measures:
A. This Policy is established for the security of special category personal data.
B. For the processes of processing special category personal data:
C. If the environment where special category personal data is processed, stored, and/or accessed is in electronic form:
D. If the environment where special category personal data is processed, stored, and/or accessed is physical:
E. If special category personal data is to be transferred:
F. In addition to the measures mentioned above, technical and administrative measures specified in our general policy on the protection of personal data are also implemented.
RUNITAS INFORMATION TECHNOLOGY INDUSTRY AND TRADE JOINT STOCK COMPANY