KVKK article 6: Personal data of special nature are data related to "sensitive areas" of the person and are subject to additional protection.
Special Nature Data
- Race, ethnic origin
- Political thought
- Philosophical belief
- Religion, sect, religious belief
- Disguise and clothing
- Association/foundation membership
- Health
- Sexual life
- Criminal convictions
- Security measures
- Biometric and genetic data
Processing Conditions
- Except for health and sexual life:Explicit consent OR being prescribed by law
- Health and sexual life: Explicit consent OR limited purposes such as public health, preventive medicine
Authorized Personnel
Personnel with obligation of confidentiality should be assigned in the unit that processes health data.
Additional Security Measures
- Encryption
- Authority limitation
- Monitoring
- Locked for paper documents outside the system storage
KVKK Board Decision
KVKK Board adopts that "explicit consent" is insufficient in the processing of biometric data (fingerprint, facial recognition) and that if an alternative method is possible, it should be preferred.
KVKK expert lawyer is recommended.