1. PURPOSE AND SCOPE
BODE Araç Kapı Sistemleri Sanayi ve Ticaret A.Ş. (“COMPANY”), for the purpose of ensuring workplace and site security, records video images 24 hours a day, 7 days a week via closed-circuit camera systems (CCTV) located at workplace entry and exit points and in common and work areas where deemed necessary.
Within this scope, images of employees, visitors, contractor/subcontractor personnel, customer and supplier representatives, and other natural persons within the camera field of view are processed under the Turkish Personal Data Protection Law No. 6698 (“KVKK”) by the COMPANY in its capacity as Data Controller.
In camera surveillance activities, the principles that personal data must be relevant to, limited to and proportionate to the purposes for which they are processed, as well as the principle of data minimization, are observed.
NO AUDIO RECORDING IS MADE THROUGH THE CAMERA SYSTEMS!
2. PURPOSES OF CAMERA SURVEILLANCE
Camera surveillance and video recording activities are carried out solely for the purposes of ensuring the security of the workplace, employees, visitors and assets belonging to the COMPANY; helping to prevent and detect unauthorized access, security breaches and other security incidents; preventing risks and incidents within the scope of occupational health and safety; examining specific security incidents and occupational accidents; and, where necessary, establishing, exercising or protecting the COMPANY’s legal rights.
Camera systems are not used for systematic monitoring of employees’ performance, work efficiency or attendance, or for general employee supervision.
3. METHOD OF COLLECTING PERSONAL DATA AND LEGAL BASIS
Camera surveillance and recording activities are carried out taking into account the COMPANY’s obligations regarding workplace security and, to the extent applicable, the provisions of Law No. 5188 on Private Security Services and the relevant legislation. Camera video recordings are collected through closed-circuit camera systems located at the workplace and site electronically and by automated means.
Video recordings are processed, depending on the nature of the activity, within the scope of Article 5 of the KVKK on the legal grounds that processing is necessary for the data controller to fulfil its legal obligation and processing is necessary for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not adversely affected.
In the event of a security incident, occupational accident, legal dispute or similar specific event, the separate retention and use of the relevant video recordings may, where the applicable conditions are met, be based on the legal ground that processing is necessary for the establishment, exercise or protection of a right.
4. SCOPE OF SURVEILLANCE, PURPOSE LIMITATION AND PROPORTIONALITY
The areas in which cameras are installed, the number and location of cameras, their viewing angles and the scope of recording are determined only to the extent necessary to achieve the purposes specified in this “Camera Information Notice”.
Wide-angle recording that is not necessary for security purposes or recording that unnecessarily focuses on persons/faces is not carried out. When camera systems are used, the reasonable expectation of privacy that persons may have even while present in the workplace is taken into account.
Camera surveillance and video recording are not carried out in toilets, changing/dressing areas, prayer rooms, rest areas or similar areas where persons have a high expectation of privacy.
5. INFORMATION AND NOTIFICATION OF CAMERA SURVEILLANCE
The COMPANY places camera information signs at appropriate points in areas where camera surveillance is carried out so that data subjects are informed before entering the camera field of view or, at the latest, when they encounter the camera surveillance activity.
Such signs clearly state that camera surveillance and video recording are carried out and provide access to this “Camera Information Notice” for detailed information.
6. RETENTION AND DESTRUCTION OF CAMERA RECORDINGS
Under normal circumstances, camera recordings are retained for 15 days from the date of recording. At the end of this period, the recordings are deleted, destroyed or rendered inaccessible by being overwritten in accordance with the technical structure of the system used.
The creation of any technical copy or backup of camera recordings, or the retrospective review of recordings, does not extend the ordinary 15-day retention period.
However, where a security incident, occupational accident, legal dispute, request from an official authority or another specific circumstance requiring the establishment, exercise or protection of a right arises, only the video recording related to the relevant incident may be separated from the ordinary recording system and retained separately only for the period necessary to investigate the incident or conduct the legal process.
Where the reasons requiring processing cease to exist, the relevant personal data is deleted, destroyed or anonymized in accordance with Article 7 of the KVKK and the COMPANY’s “Personal Data Retention and Destruction Policy”.
7. SECURITY AND STORAGE ENVIRONMENT OF CAMERA RECORDINGS
Camera recordings are retained on physical servers located within the COMPANY. Access to camera recordings is restricted in accordance with job and authorization requirements, and access is permitted only to authorized persons. Necessary administrative and technical measures are implemented under Article 12 of the KVKK to prevent unauthorized persons from viewing, copying, modifying, transferring or using the recordings for purposes other than those intended.
8. TRANSFER OF PERSONAL DATA AND TRANSFER ABROAD
Camera recordings may, for the purposes of investigating a security incident or legal process, fulfilling legal obligations or responding to lawful requests from competent authorities, and within the conditions stipulated in Article 8 of the KVKK, be shared with authorized public institutions and organizations, law enforcement authorities, and judicial and administrative authorities.
Camera recordings are not shared with unauthorized third parties except in the circumstances specified above.
CAMERA RECORDINGS ARE NOT TRANSFERRED ABROAD!
9. RIGHTS UNDER THE KVKK
You may submit requests concerning your rights under Article 11 of the KVKK to the COMPANY by using the “Data Subject Application Form” available on the COMPANY’s website and in accordance with the applicable application procedures and principles. KVKK Article 11 provides you with the following rights in relation to your personal data:
- to learn whether your personal data is being processed
- to request information if your personal data has been processed
- to learn the purpose of processing your personal data and whether it is used in accordance with that purpose
- to know the third parties to whom your personal data has been transferred in Türkiye or abroad
- to request the correction of your personal data if it has been processed incompletely or inaccurately, and to request that the action taken in this respect be notified to third parties to whom the personal data has been transferred
- to request the deletion or destruction of your personal data where the reasons requiring its processing cease to exist, even though it has been processed in accordance with the KVKK and other relevant laws, and to request that the action taken in this respect be notified to third parties to whom the personal data has been transferred
- to object to any result arising against you as a result of the analysis of processed data exclusively by automated systems
- to claim compensation for damages where you suffer loss as a result of the unlawful processing of your personal data
10. APPLICATION METHODS
As personal data subjects, you may submit your requests arising from your statutory rights under the relevant law and other legislation by completing application form / petition that can be found under the link https://www.bode-global.com.tr/en/kvkk:
“Kale Mahallesi Burçak Sokak No: 3 | PK: 16450 | Kestel / BURSA” to our address, together with documents verifying your identity and bearing a wet-ink signature, in person or through a notary public,
“Communiqué on the Procedures and Principles of Application to the Data Controller”, pursuant to Article 5, by using a registered electronic mail (KEP) address, secure electronic signature or mobile signature; electronically to our KEP e-mail address [email protected] electronically,
Using the e-mail address previously notified to the COMPANY and registered in the COMPANY systems, you may submit your application to our official e-mail address [email protected] together with documents verifying your identity and a wet-ink signed copy, electronically.
If you submit your request to us using one of these methods, pursuant to Article 13 of the KVKK, it will be evaluated and concluded as soon as possible depending on the nature of the request and, in any event, no later than 30 days, and you will be informed accordingly. If your request is accepted, the necessary actions will be carried out without delay by the data controller COMPANY.
NOTE: APPLICATIONS ARE, AS A RULE, CONCLUDED FREE OF CHARGE; HOWEVER, WHERE PROCESSING OF THE APPLICATION ENTAILS AN ADDITIONAL COST, THE FEE SPECIFIED IN THE TARIFF DETERMINED BY THE BOARD UNDER THE “COMMUNIQUÉ ON THE PROCEDURES AND PRINCIPLES OF APPLICATION TO THE DATA CONTROLLER” MAY BE CHARGED.
11. DATA CONTROLLER AND CONTACT
DATA CONTROLLER: BODE ARAÇ KAPI SİSTEMLERİ SANAYİ ve TİCARET A.Ş.
ADDRESS: Kale Mahallesi Burçak Sokak No:3 | PK:16450 | Kestel / BURSA
WEBSITE: www.bode-global.com.tr
E-MAIL: [email protected]
KEP ADDRESS: [email protected]
TELEPHONE: +90 (224) 373 20 00
CONTACT PERSON: Enver Bayrak
12. UPDATES TO THE NOTICE
This “Camera Information Notice” may be updated in line with changes in legislation, decisions of the Personal Data Protection Board, changes in the COMPANY’s camera systems or personal data processing activities, or other legal and operational requirements. The current version of this Notice is published in the COMPANY’s KVKK section of its website. Where a change in personal data processing activities carried out through cameras is of such a nature that separate notification to data subjects is required, the necessary information shall additionally be provided in accordance with the KVKK and the relevant legislation.