WORKPLACE SURVEILLANCE THROUGH SECURITY CAMERAS

On 8 June 2026, the Personal Data Protection Authority (“Authority”) published a public announcement on matters to be considered in the use of security camera systems in workplaces.

Workplaces acting as data controllers are obliged to safeguard the fundamental rights and freedoms of individuals whose personal data they process. Article 417 of the Turkish Code of Obligations, entitled “Protection of the Employee’s Personality”, provides as follows:

“The employer is obliged to protect and respect the personality of the employee within the employment relationship and to maintain an order in the workplace that is consistent with the principles of good faith. In particular, the employer must take the necessary measures to prevent employees from being subjected to psychological or sexual harassment and to ensure that those who have been exposed to such harassment do not suffer further harm.The employer is also required to take all necessary measures to ensure occupational health and safety in the workplace and to provide all necessary equipment and tools in full. Employees, in turn, are obliged to comply with all occupational health and safety measures implemented by the employer.”

While the use of workplace security camera systems may be justified for the fulfilment of employers’ legal obligations, the personal data processing activities carried out through such systems must be conducted in compliance with Law No. 6698 on Personal Data Protection (the “Law”) and especially by taking the considerations set out below:

• Security cameras may only be used for specific, explicit, and legitimate purposes, such as ensuring workplace security, protecting occupational health and safety, preventing workplace accidents, and assisting in the prevention and detection of crimes.
• Using cameras to monitor employees’ performance, productivity, discipline, or for general surveillance purposes is not considered a legitimate purpose.
• When installing camera systems, the principles of proportionality and data minimization must be observed, and surveillance should be limited to areas where it is genuinely necessary.
• Cameras should not be installed in areas where individuals have a heightened expectation of privacy, such as restrooms, changing rooms, prayer rooms, or employee rest areas.
• Audio recording through security cameras is regarded as a highly intrusive measure and should not be used unless there is a clear legal basis and a demonstrable necessity.
• Employees and other affected individuals must be properly informed that camera surveillance is taking place, in accordance with the information obligation under the Law.
• Camera recordings should be retained only for the period strictly necessary, should not be stored longer than required, and should preferably be subject to automatic deletion mechanisms.
• Access to camera recordings must be restricted to authorized personnel, and appropriate technical and administrative measures must be implemented to ensure data security.
• Failure to comply with these obligations may result in administrative fines and other legal sanctions under the Law.

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