Personal data processing activities carried out by ÖZEL ISPARTAKULE SUN ANAOKULU [FULYA KOÇALİ] (the “School”) at building and facility entrances and inside the facilities are conducted in accordance with the Constitution of the Republic of Türkiye, the Law on the Protection of Personal Data (the “PDP Law” / KVKK) and other applicable legislation. As data controller under the KVKK, and for the purpose of ensuring security, the School carries out personal data processing activities consisting of monitoring by security cameras in its buildings and facilities and tracking the entries and exits of students, parents, visitors, subcontractors and their vehicles.
Through the use of security cameras and the recording of student/parent/visitor entries and exits, the School carries out personal data processing activities in its capacity as data controller.
Camera Monitoring and Recording Activities at School Building and Facility Entrances and Inside the Facilities
To ensure legal, technical and commercial operational security, the School processes personal data by capturing images through a closed-circuit camera system (CCTV) on School premises.
Legal Basis of the Camera Monitoring Activity
The camera monitoring and recording activity carried out by the School is conducted in accordance with Law No. 5188 on Private Security Services and its implementing regulation, on the legal ground of the School’s legitimate interest, and pursuant to the provisions of the Regulation on Preschool Education Institutions.
Personal data are collected electronically via closed-circuit camera systems for the purpose of ensuring the security of School buildings, within the framework of the personal data processing conditions set out in Articles 5 and 6 of the KVKK.
Security Camera Monitoring Under Personal Data Protection Law
The School conducts security camera monitoring in its buildings and facilities in accordance with the personal data processing conditions listed in the KVKK, for the purposes envisaged in the applicable legislation in force and for ensuring legal, technical and commercial operational security.
Information Notice Regarding the Camera Monitoring Activity
The School informs data subjects in accordance with Article 10 of the KVKK.
The School provides notice of the camera monitoring activity through more than one method. In this way, it is intended to prevent harm to the fundamental rights and freedoms of the data subject and to ensure transparency and proper information of the data subject.
A notice stating that monitoring is carried out is posted at the entrances of the areas of School buildings and facilities where camera monitoring takes place. In addition, along with that notice, the channels through which this detailed privacy notice can be accessed are shared with the data subject.
Purpose of the Camera Monitoring Activity and Purpose Limitation
In accordance with Article 4 of the KVKK, the School processes personal data in a manner that is connected with, limited to and proportionate to the purpose of ensuring security, in terms of the monitoring areas, number and timing of the security cameras.
The purpose of the School’s closed-circuit camera monitoring activity is limited to those set out in this Policy.
Areas where monitoring could result in an intrusion into a person’s privacy beyond security purposes (for example, changing rooms, toilets, etc.) are not subject to monitoring. In accordance with the Regulation on Preschool Education Institutions, monitoring activities are carried out in a manner that does not violate student privacy.
Ensuring the Security of the Data Obtained
In accordance with Article 12 of the KVKK, the School takes the necessary technical and administrative measures to ensure the security of personal data obtained as a result of camera monitoring. In this context, the number of personnel authorized to access the recordings is limited, and a written undertaking regarding the protection of the relevant data is obtained from these persons.
Retention Period of Personal Data Obtained Through Camera Monitoring
Personal data recorded by the School’s cameras are retained for a minimum of 60 days, and this period may extend up to a maximum of 120 days. Disposal of the relevant data is carried out in accordance with the School’s “Personal Data Retention and Disposal Policy”.
To Whom and for What Purposes the Personal Data Obtained May Be Transferred
Camera footage may be transferred to authorized public institutions in accordance with the legislation, for the purpose of ensuring the security of School buildings, within the framework of the personal data processing conditions and purposes set out in Articles 8 and 9 of the KVKK (for example, upon the written request of a public prosecutor or judge during the investigation of an incident). The limited number of persons with access to the recordings declare, through a personnel confidentiality undertaking, that they will protect the confidentiality of the data they access.
Purposes of Processing, Categorization and Retention Periods of the Personal Data Processed
In accordance with its information obligation under Article 10 of the KVKK, the School informs data subjects of which personal data of which data subject groups it processes, the purposes of processing and the retention periods. In this context, the School is registered in the Data Controllers’ Registry, which is public (except in the exceptional cases determined by the Personal Data Protection Board) and open to access by data subjects.
Deletion, Destruction and Anonymization of Personal Data
Detailed information on the disposal processes and disposal methods for your data processed as a result of camera monitoring is provided on the School’s website under the heading “Personal Data Retention and Disposal Policy”.
Rights of the Data Subject Listed in Article 11 of the KVKK
Pursuant to Article 11 of the PDP Law, data subjects have the following rights:
- To learn whether their personal data are being processed
- To request information regarding the personal data processed
- To learn the purpose of processing of their personal data and whether they are used in accordance with that purpose
- To know the third parties to whom their personal data are transferred, whether domestically or abroad
- To request the correction of their personal data if processed incompletely or inaccurately, and to request that the action taken in this context be notified to the third parties to whom the personal data have been transferred
- To request the deletion or destruction of their personal data if the reasons requiring processing cease to exist, even though the data have been processed in accordance with the Law and other applicable legal provisions, and to request that the actions taken in this context — as well as any corrections of incomplete or inaccurate processing — be notified to the third parties to whom the personal data have been transferred
- To object to the occurrence of a result to their detriment arising from the analysis of the processed data exclusively through automated systems
- To request compensation for damages incurred due to the unlawful processing of their personal data
How to Exercise Your Rights
You may submit requests regarding the rights listed above by filling in the Data Subject Application Form available on the School’s website, through the following channels:
- By email: to e-posta
- By registered electronic mail (KEP): to e-posta
- By notary or registered return-receipt mail: to the School’s registered address
- By hand delivery: signed, to the School’s address
- With a secure electronic signature: by sending a signed file in Word or PDF format
Depending on the nature of your request, your applications will be concluded free of charge as soon as possible and within thirty days at the latest; however, if the process additionally requires a cost, a fee may be requested from you according to the tariff to be determined by the Personal Data Protection Board.