3 principles in employee monitoring: proportionality, purpose limit, transparency.
Legal basis
- Legitimate interest (KVKK article 5/2-f).
- Contractual obligation.
Transparency
- Notification of start of work.
- Policy document signed.
- Annual update.
Proportionality
- Depends on business purpose (personal e-mail is not filtered).
- Keyloggers are generally excessive.
- Workplace entry instead of permanent cameras.
Frequently asked
Is the employee's private email monitored?
Usually no; business account yes.
Toilet camera?
Absolutely forbidden.
Instant screen recording?
Risk; Limited for special mission.
Relevant legislation
- KVKK no. 6698 article 12 — Data security obligation; notice of violation (art.12/5).
- KVKK no. 6698 article 14 — Right to compensation.
- KVKK no. 6698 article 18 — Administrative fine (up to 5 million TL).
- GDPR Art. 33-34 — 72-hour infringement notification on EU cross-border transfer.
- TCK art.135-136 — Unlawful recording/dissemination of personal data.
Legal notice: This article is for general information purposes; A meeting with a lawyer is required for a concrete case.