Camera recordings (CCTV) process personal data and are within the scope of KVKK. Lighting and compliance are a must.
Lighting
- Visible warning signs
- "This area is monitored by security cameras" text
- Data controller name + contact
- Purpose: security / protection of life and property
Legal Basis
- Legitimate interest (KVKK) Art.5/2-f)
- Legal obligation (Art.5/2-d) in some sectors
- Explicit consent is generally not required (in public area)
Storage Period
- Generally between 15-30 days
- If an incident occurs, a record of the event is kept
- In case of request of the judicial authorities extension
Areas that should not be monitored
- Toilet, locker room
- Employee rest rooms (controversial)
- Areas that interfere with private life
Third Party Requests
- A person can request the recording of his/her own image
- The image of others should be masked
- Judicial authorities requests are exceptions It requires a response within the "period" and sanctions malicious monitoring or storage extension with an administrative fine.
KVKK expert lawyer is recommended.