Camera Recordings Privacy Notice

This PRIVACY NOTICE ON CAMERA RECORDINGS UNDER PERSONAL DATA PROTECTION LAW NO. 6698 (the “Privacy Notice”) has been prepared by ANKARA MEDİPOL UNIVERSITY (the “University”), in its capacity as Data Controller and within the framework of the Personal Data Protection Law No. 6698 (“KVKK”) and related legislation. Its purpose is to inform students, academic and administrative staff, persons working as consultants or in other capacities, patients and their relatives, contractors and their representatives, employees and other related parties, guests and other persons who are in contact with the University (“Data Subject(s)”), including you as a Data Subject, about the collection, processing and transfer of personal data through camera recording at the University's campuses, health practice and research centers, dormitory buildings, other service buildings, open and enclosed areas such as gardens, entrance and exit gates, car parks, security booths, dining halls, visitor waiting areas, floor corridors, classrooms, building exteriors and facilities, vehicles and event areas (“Camera Recording Locations”).

The camera monitoring and recording activity carried out by the University is performed by capturing images of the entries and exits of Data Subject(s) and their vehicles at the Camera Recording Locations through a closed-circuit camera system (CCTV).

The University processes the personal data of Data Subject(s) obtained through CCTV imaging in order to fulfill the legal obligations expressly set forth in the Labor Law No. 4857, the Occupational Health and Safety Law No. 6331, the Law No. 5188 on Private Security Services and secondary legislation, including but not limited to the regulations and communiqués issued on the basis of these laws, and to protect the legitimate interests of the University. This processing is based on the following legal grounds: “being expressly provided for by law” under subparagraph (a) of paragraph 2 of Article 5 of the KVKK; “being necessary for the data controller to fulfill its legal obligation” under subparagraph (ç) of paragraph 2 of Article 5 of the KVKK; “data processing being necessary for the establishment, exercise or protection of a right” under subparagraph (e) of paragraph 2 of Article 5 of the KVKK; and “data processing being necessary for the legitimate interests of our institution as the data controller” under subparagraph (f) of paragraph 2 of Article 5 of the KVKK.

In processing your personal data, our University acts in accordance with the data processing principles and obligations set out in the relevant legislation, in particular the Constitution of the Republic of Türkiye, the international conventions to which the Republic of Türkiye is a party, the KVKK, the secondary legislation issued pursuant to the KVKK, and the guidelines and principle decisions published by the Personal Data Protection Authority.

Within the scope of security camera monitoring at the Camera Recording Locations (through closed-circuit camera systems), personal data are collected by monitoring and recording the entries and exits of Data Subject(s) and their vehicles, within the framework of the personal data processing conditions specified in Article 5 of the KVKK.

Personal data collected at the Camera Recording Locations for the realization of the legal grounds stated above are processed within the framework of the personal data processing conditions specified in Articles 5 and 6 of the KVKK. This processing is based on the legal grounds of “being necessary for the data controller to fulfill its legal obligation”, “data processing being necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject” and “being expressly provided for by law”. It is carried out for the purposes listed below and in accordance with the principle set forth in Article 4 of the KVKK that personal data shall be processed in a manner that is relevant, limited and proportionate to the purposes for which they are processed:

Under the service contract: fulfilling service obligations, fulfilling employer responsibilities, conducting disciplinary procedures, ensuring occupational safety, and managing, supervising and performing work,
Preparing all records and documents that will serve as the basis for processing in electronic (internet/mobile, etc.) or physical media,
Providing information to public officials upon request and as required by legislation on matters concerning public safety,
Fulfilling legal obligations and exercising rights arising from the legislation in force,
Fulfilling legal obligations where the relevant authority requests information within the scope of judicial and administrative investigations and a response is mandatory,
Conducting occupational health and safety activities,
Conducting assignment processes,
Providing information to authorized persons, institutions and organizations,
Conducting emergency management processes,
Organization and event management,
Conducting information security processes,
Conducting storage and archiving activities,
Ensuring the security of physical premises.
Determining and monitoring entry and exit times.

Accordingly, the purpose of the University's closed-circuit camera monitoring activity is limited to the purposes listed in this Privacy Notice. The monitoring areas and number of security cameras, as well as the times when monitoring is carried out, are determined to the extent sufficient for, and limited to, achieving the security purpose.

Areas where monitoring could result in an intrusion into personal privacy beyond security purposes (e.g., changing rooms, toilets, etc.) are not subject to monitoring.

The University informs Data Subject(s) as personal data owners in accordance with Article 10 of the KVKK.

With regard to its camera monitoring activity, the University posts notices at the entrances of the buildings and campuses where monitoring is carried out, indicating that monitoring is in place.

In order to prevent harm to the fundamental rights and freedoms of Data Subject(s) while their images are obtained through camera monitoring/recording, and to ensure transparency and inform personal data owners, Data Subject(s) are informed by means of notices posted at the entrances of the buildings and campuses where monitoring is carried out and through the texts provided on www.medipol.edu.tr.

In accordance with Article 12 of the KVKK, the University takes the necessary technical and administrative measures to ensure the security of personal data obtained through camera monitoring.

Personal data obtained/recorded through camera monitoring will be retained in accordance with the law for the maximum period specified in the relevant legislation or required for the purpose for which they are processed, and in any case for the duration of the statutory limitation periods. The retention period for personal data obtained by camera at the University is 2 months.

Although the personal data covered by this Privacy Notice have been processed in accordance with the provisions of the relevant law, as regulated in Article 138 of the Turkish Penal Code and Article 7 of the KVKK, the personal data will be erased, destroyed or anonymized by the University, either on its own decision or upon the request of the personal data owner, if the reasons requiring their processing cease to exist.

Detailed information on the transfer of collected and processed personal data is available in VERBİS under the headings “Data Transfer Recipient Groups” and “Information to Be Transferred Abroad”.

Only a limited number of employees have access to the information obtained through monitoring.

Within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK, in order to achieve the purposes listed above, and provided that adequate and effective measures are taken in accordance with the security and confidentiality principles set out in the legislation, the said personal data may be transferred as follows so that the University can fulfill its obligations arising from the legislation:

to the private security service company and the company that installs or operates the technical infrastructure, for the purpose of ensuring occupational health and safety at the Camera Recording Locations and determining and monitoring the entry and exit times of students, academic and administrative staff, guests, patients, contractors and other persons (Data Subject(s)),
to authorized external providers for the management and storage of data,
to experts, independent audit firms, law firms and auditing companies for audit and due diligence activities, and to public institutions, insurance companies, business consultants, and natural or legal persons or organizations with which we cooperate for the fulfillment of regulatory and contractual obligations,
to official institutions such as the police, public prosecutor's offices and courts if camera recordings are requested,
to judicial authorities or relevant law enforcement agencies for the resolution of legal disputes or upon request as required by the relevant legislation,
to authorized administrative and supervisory boards and/or other authorized supervisory institutions, limited to the personal data processing conditions and the purposes stated above.

Your camera recording data will not be shared with third parties or transferred abroad except in the cases listed above. Should it become necessary to transfer your personal data to any third party other than in the cases specified above, you will be informed separately.

The limited number of persons with access to the recordings declare, by means of a confidentiality undertaking, that they will protect the confidentiality of the data they access.

Subject to the cases set forth in Article 28 of the KVKK titled “Exceptions”, by applying to our University within the framework of Article 11 of the KVKK, you have the right to:

a. learn whether your personal data are processed,

b. request information if they have been processed,

c. learn the purpose of processing and whether they are used in accordance with that purpose,

d. know the third parties to whom they are transferred domestically or abroad,

e. request their rectification if they are incomplete or inaccurately processed,

f. request the erasure or destruction of your personal data within the framework of the conditions set forth in Article 7 of the KVKK,

g. request that the operations carried out pursuant to subparagraphs (e) and (f) be notified to the third parties to whom the personal data have been transferred,

h. object to any result against you arising from the analysis of the data exclusively through automated systems,

i. request compensation for damages if you suffer damage due to the unlawful processing of your personal data.

Applications may be submitted in writing or electronically using the methods below after completing the “KVKK Data Subject Application Form” available on the University's website.

Your personal data are meticulously protected within the scope of technical and administrative means, and the necessary security measures are ensured at a level appropriate to potential risks, taking technological possibilities into account. In accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, you may submit your requests regarding your personal data under the Law to the University through the channels below by completing the “KVKK Data Subject Application Form” referred to in this Privacy Notice:

	Application Method	Application Address	Application Information
1	In person, with a handwritten signed application and a valid identity document, or through a notary public	Ankara Medipol University Hacı Bayram Mahallesi Talatpaşa Bulvarı No:2 Altındağ / Ankara	"Application under the KVKK" must be written on the envelope or notification.
2	Via your Registered Electronic Mail (KEP) address	[email protected]	"Application under the KVKK" must be written in the subject line of the e-mail.
3	Via your e-mail address registered in the University's system	[email protected]	"Application under the KVKK" must be written in the subject line of the e-mail.
4	Via an e-mail address not registered in the University's system, including a secure electronic signature or mobile signature	[email protected]	"Application under the KVKK" must be written in the subject line of the e-mail.

If you are applying on behalf of another person, you must attach the following to your application together with your own identity information: (i) a civil registry record or relevant document showing your relationship with, and authority over, the person of whom you are the parent or guardian; (ii) in other cases, a copy of the power of attorney specifically authorizing you.

Pursuant to the Communiqué on the Procedures and Principles of Application to the Data Controller, the application must contain the following information:

Name, surname and, if the application is in writing, signature,
T.R. identity number for citizens of the Republic of Türkiye; nationality, passport number or identity number, if any, for foreign nationals,
Residential or business address for notification purposes,
E-mail address, telephone and fax number for notification purposes, if any,
Subject of the request.

Camera Recordings Privacy Notice

Privacy Notice on Camera Recordings under Personal Data Protection Law No. 6698

1- Methods and Legal Grounds for Collecting Personal Data

2- Purpose of Processing Personal Data

3- Notification of Camera Monitoring Activity

4- Ensuring the Security of the Data Obtained

5- Retention Period of Personal Data Obtained through Camera Monitoring

6- Erasure, Destruction and Anonymization of Personal Data

7- To Whom and for What Purposes Personal Data May Be Transferred

8- Legal Rights Regarding the Protection of Personal Data

9- Exercising Legal Rights Regarding Personal Data

Ankara Medipol University KVKK Application Form

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