The Personal Data Protection Authority ("Authority") published Guidelines on the Processing of Turkish Republic Identity Numbers ("Guidelines") on January 16, 2024.
The Guideline emphasizes that the Authority has received many complaints that the direct processing of Turkish Republic ID numbers is being preferred by data controllers/processors while other methods are possible. In this context, since the main purpose of the Law No. 6698 on the Protection of Personal Data ("Law") is to protect the fundamental rights and freedoms of individuals, it is emphasized that data processing activities should be limited in a way to cause minimum interference with such rights, and it is pointed out that the Turkish ID number has an important place since it is not special personal data, but it can also provide access to other personal data.
The Authority states in the Guideline that the use of the Turkish ID number in this way is contrary to the principle of "being connected, limited and proportionate to the purpose for which it is processed" in Article 4 of the Law. In this context, it is stated that methods that interfere less with the right to protection of personal data of data subjects should be preferred in the processing of the Turkish ID number.
Finally, in the Guidelines, the situations foreseen in the legislation regarding the use of the Turkish ID number are compiled under the following headings below:
- Cases where the legislation stipulates the processing of the Turkish ID number: Invoicing for the purchase of goods/services, ordering/cargo delivery, registration in the trade registry, requesting execution proceedings, notary procedures, etc.
- Situations related to the submission, display or notification of documents/identity information containing the Turkish ID number to the competent authorities for identification and other purposes: Situations such as participation in the general assembly of the company where the relevant person is a shareholder, making distance contracts, voting in elections, electronic payments are listed.
The full text of the Guideline is available at the following link (in Turkish):
https://kvkk.gov.tr/SharedFolderServer/CMSFiles/a828de56-b2b2-43bf-b77d-cc05de5b2c84.pdf
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