This is an English translation provided for convenience. In the event of any discrepancy, the Turkish version of this document prevails.
ÜRMAKSAN CCTV PRIVACY NOTICE
INFORMATION NOTICE ON CAMERA RECORDINGS UNDER LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA
The personal data processing activities carried out by Ürmaksan Mak. San. Taah. Tic. Ltd. Şti. at building entrances and inside its facilities are conducted in accordance with the Constitution of the Republic of Turkey, the Law on the Protection of Personal Data (PDPL) and other relevant legislation.
Legal Basis of Camera Monitoring and Method of Collecting Personal Data
Video recording is carried out for the purpose of ensuring building security by means of a total of 55 security cameras located at the entrance doors inside Ürmaksan buildings, the garden, the building façade, the canteen, offices, the training hall and archive entrance, the visitor waiting area, the car park, the security booth, floor corridors and the production area. The recording process is supervised by the “Ürmaksan Personal Data Protection Committee”.
Conducting Security Camera Monitoring in Accordance with Personal Data Protection Law
Ürmaksan carries out security camera monitoring for the purpose of ensuring security in its buildings and production area, for the purposes prescribed in the applicable legislation and in accordance with the personal data processing conditions listed in the PDPL.
Announcement of Camera Monitoring
In accordance with Article 10 of the PDPL, the data subject is informed. In addition to the information it provides on general matters, Ürmaksan issues notices regarding camera monitoring through more than one method. The aim is to prevent harm to the fundamental rights and freedoms of the data subject and to ensure transparency and the proper informing of the data subject. To this end, Ürmaksan posts notice signs at the entrances to the areas where monitoring takes place.
Purpose and Processing of Camera Monitoring
In accordance with Article 4 of the PDPL, Ürmaksan processes personal data in a manner relevant, limited and proportionate to the purposes for which it is processed. The purpose of maintaining closed-circuit camera monitoring at Ürmaksan is limited to the purposes listed in this Policy. Accordingly, the monitoring areas, the number of security cameras and the times at which monitoring takes place are implemented so as to be sufficient for, and limited to, achieving the security objective. Areas where monitoring could constitute an intrusion into privacy beyond security purposes (for example, changing rooms, washbasins, toilets and similar) are not monitored.
Ensuring the Security of the Data Obtained
In accordance with Article 12 of the PDPL, Ürmaksan takes the necessary technical and administrative measures to ensure the security of the personal data obtained as a result of camera monitoring.
Retention Period of Personal Data Obtained Through Camera Monitoring
The retention period for personal data obtained by Ürmaksan through cameras is 15 days.
To Whom and For Which Purposes the Personal Data Obtained May Be Transferred
A limited number of employees have access to the information obtained as a result of monitoring. Camera footage may be transferred to authorised public institutions in accordance with legislation, for the purpose of ensuring the security of Ürmaksan’s sites and buildings, within the framework of the personal data processing conditions and purposes set out in Article 8 of the PDPL. The limited number of persons who have access to the recordings declare, by way of a confidentiality agreement, that they will protect the confidentiality of the data they access. The personal data in question may be transferred to judicial authorities or the relevant law enforcement agencies upon request, for the resolution of legal disputes or as required by the relevant legislation.