Special category personal data
Definition
Special category personal data are the types of data listed in Article 6 of KVKK and protected by stricter rules. Health data, biometric data and genetic data all fall into this group.
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Which data are special category?
The law lists them one by one: data on race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, membership of associations, foundations or trade unions, health, sex life, criminal convictions and security measures, plus biometric and genetic data. In a clinic, health data comes first: the complaint, medication, long-term conditions, X-rays and pre-treatment photos.
What did the 2024 amendment change?
Law No. 7499 of 2 March 2024 rewrote Article 6, with effect from 1 June 2024.
- Processing special category data is prohibited unless one of the listed conditions applies.
- The conditions include explicit consent, express provision in law, protecting someone's life, establishing a right, and processing by people under a duty of confidentiality for medical diagnosis, treatment and care.
- In every case the Board's adequate measures must be in place too: access limited to those whose work needs it, protected files, and data kept no longer than its purpose requires.
- Ask your lawyer which condition fits your work.
Sources
- Law No. 6698 on the Protection of Personal Data (Turkish text) — Mevzuat Bilgi Sistemi, Official Gazette, 7 April 2016
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