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TDPL - EMPLOYEE PRIVACY NOTICE
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1. PURPOSE AND SCOPE

BODE Araç Kapı Sistemleri Sanayi ve Ticaret A.Ş. (“COMPANY”), attaches importance to the privacy and security of its employees’ personal data and processes personal data within the scope of the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and the relevant legislation in its capacity as Data Controller.

This “Employee Information Notice” has been prepared by the COMPANY to provide information, pursuant to Article 10 of the KVKK, on personal data processed in connection with the establishment, performance and termination of the employment relationship between the COMPANY and the employee.

COMPANY processes personal data in a manner that is lawful and fair, accurate and, where necessary, up to date, for specified, explicit and legitimate purposes, relevant to, limited to and proportionate to the purposes for which they are processed, and for no longer than the period prescribed by the relevant legislation or required for the purpose of processing.


2. PERSONAL DATA PROCESSED, PURPOSES OF PROCESSING AND LEGAL BASES


  • DATA CATEGORY: IDENTITY
  • MAIN PERSONAL DATA PROCESSED: NAME AND SURNAME, TURKISH IDENTITY NUMBER AND ID CARD SERIAL NUMBER, GENDER, MARITAL STATUS, DATE/PLACE OF BIRTH, PLACE OF CIVIL REGISTRATION, MOTHER'S/FATHER'S NAME, SIGNATURE
  • MAIN PURPOSES OF PROCESSING: ESTABLISHMENT AND PERFORMANCE OF THE EMPLOYMENT CONTRACT, CREATION OF THE PERSONNEL FILE, FULFILMENT OF STATUTORY OBLIGATIONS, NOTIFICATIONS TO AUTHORIZED INSTITUTIONS AND ORGANIZATIONS
  • LEGAL BASIS: PROCESSING BEING DIRECTLY RELATED TO AND NECESSARY FOR THE ESTABLISHMENT OR PERFORMANCE OF A CONTRACT; PROCESSING BEING NECESSARY FOR THE DATA CONTROLLER TO FULFIL ITS LEGAL OBLIGATIONS


  • DATA CATEGORY: CONTACT AND ADDRESS
  • MAIN PERSONAL DATA PROCESSED: TELEPHONE NUMBER, E-MAIL ADDRESS, REGISTERED ELECTRONIC MAIL ADDRESS (KEP), RESIDENTIAL / CONTACT ADDRESS
  • MAIN PURPOSES OF PROCESSING: MANAGEMENT OF THE EMPLOYMENT RELATIONSHIP AND COMMUNICATION PROCESSES, EMERGENCY MANAGEMENT, NOTIFICATIONS AND PROCEDURES ARISING FROM LEGISLATION
  • LEGAL BASIS: PROCESSING BEING DIRECTLY RELATED TO AND NECESSARY FOR THE ESTABLISHMENT OR PERFORMANCE OF A CONTRACT; FULFILMENT OF LEGAL OBLIGATIONS


  • DATA CATEGORY: PERSONNEL AND EMPLOYMENT INFORMATION
  • MAIN PERSONAL DATA PROCESSED: SALARY, LEAVE, ABSENCE, COMMENCEMENT/TERMINATION OF EMPLOYMENT, OVERTIME AND TIMEKEEPING, RETIREMENT, PAYROLL/PAY SLIP, RESUME/CV, ATTENDANCE RECORDS, DISCIPLINARY AND EMPLOYMENT RECORDS, EDUCATION DOCUMENTS, DOCUMENTS REQUIRED BY LAW TO BE KEPT IN THE PERSONNEL FILE
  • MAIN PURPOSES OF PROCESSING: MANAGEMENT OF EMPLOYMENT AND PERSONNEL PROCESSES, SALARY/PAYROLL PROCEDURES, WORK AND ATTENDANCE MONITORING, HUMAN RESOURCES PROCESSES AND STATUTORY OBLIGATIONS
  • LEGAL BASIS: EXPRESSLY PROVIDED FOR BY LAW; PROCESSING BEING RELATED TO AND NECESSARY FOR THE ESTABLISHMENT OR PERFORMANCE OF A CONTRACT; FULFILMENT OF LEGAL OBLIGATIONS; LEGITIMATE INTERESTS OF THE COMPANY


  • DATA CATEGORY: FAMILY MEMBERS AND CLOSE RELATIVES
  • MAIN PERSONAL DATA PROCESSED: SPOUSE AND CHILD INFORMATION
  • MAIN PURPOSES OF PROCESSING: MANAGEMENT OF PAYROLL, PERSONNEL, SOCIAL ENTITLEMENT AND FRINGE BENEFIT PROCESSES
  • LEGAL BASIS: PROCESSING BEING NECESSARY FOR THE DATA CONTROLLER TO FULFIL ITS LEGAL OBLIGATIONS


  • DATA CATEGORY: PROFESSIONAL EXPERIENCE AND EDUCATION
  • MAIN PERSONAL DATA PROCESSED: SOCIAL SECURITY (SGK) SERVICE RECORD, DIPLOMA, CERTIFICATES, PROFESSIONAL QUALIFICATION AND TRAINING DOCUMENTS
  • MAIN PURPOSES OF PROCESSING: MANAGEMENT OF COMPETENCY AND HUMAN RESOURCES PROCESSES, PLANNING OF IN-SERVICE TRAINING, FULFILMENT OF STATUTORY TRAINING AND QUALIFICATION OBLIGATIONS
  • LEGAL BASIS: EXPRESSLY PROVIDED FOR BY LAW; LEGITIMATE INTERESTS OF THE COMPANY


  • DATA CATEGORY: MILITARY SERVICE STATUS
  • MAIN PERSONAL DATA PROCESSED: MILITARY SERVICE STATUS DOCUMENT AND RELATED RECORDS
  • MAIN PURPOSES OF PROCESSING: MANAGEMENT OF HUMAN RESOURCES AND PERSONNEL PROCESSES
  • LEGAL BASIS: LEGITIMATE INTERESTS OF THE COMPANY


  • DATA CATEGORY: FINANCIAL DATA
  • MAIN PERSONAL DATA PROCESSED: BANK AND IBAN INFORMATION, SALARY AND PAYMENT INFORMATION
  • MAIN PURPOSES OF PROCESSING: PAYMENT OF SALARY AND OTHER EMPLOYEE PAYMENTS, MANAGEMENT OF PAYROLL, FINANCE AND ACCOUNTING PROCESSES
  • LEGAL BASIS: PROCESSING BEING NECESSARY FOR THE DATA CONTROLLER TO FULFIL ITS LEGAL OBLIGATIONS


  • DATA CATEGORY: LEGAL TRANSACTION DATA
  • MAIN PERSONAL DATA PROCESSED: WAGE GARNISHMENT DOCUMENTS, DOCUMENTS RECEIVED FROM JUDICIAL / ADMINISTRATIVE AUTHORITIES, INFORMATION CONTAINED IN DOCUMENTS RELATING TO LITIGATION AND / OR ENFORCEMENT PROCEEDINGS, INFORMATION CONTAINED IN CORRESPONDENCE WITH JUDICIAL AUTHORITIES
  • MAIN PURPOSES OF PROCESSING: FULFILMENT OF LEGAL OBLIGATIONS, MANAGEMENT OF LITIGATION AND ENFORCEMENT PROCEEDINGS AND THE COMPANY'S LEGAL AFFAIRS
  • LEGAL BASIS: PROCESSING BEING NECESSARY FOR THE DATA CONTROLLER TO FULFIL ITS LEGAL OBLIGATIONS; LEGITIMATE INTERESTS OF THE COMPANY


  • DATA CATEGORY: VISUAL AND AUDIO RECORDS
  • MAIN PERSONAL DATA PROCESSED: PASSPORT-STYLE PHOTOGRAPH AND OTHER NECESSARY VISUAL RECORDS CREATED WITHIN THE SCOPE OF THE EMPLOYMENT RELATIONSHIP
  • MAIN PURPOSES OF PROCESSING: MANAGEMENT OF PERSONNEL AND ONBOARDING PROCEDURES, NOTIFICATIONS REQUIRED TO BE MADE TO AUTHORIZED AUTHORITIES
  • LEGAL BASIS: PROCESSING BEING RELATED TO AND NECESSARY FOR THE ESTABLISHMENT OR PERFORMANCE OF A CONTRACT


  • DATA CATEGORY: PHYSICAL PREMISES SECURITY
  • MAIN PERSONAL DATA PROCESSED: WORKPLACE ENTRY-EXIT AND SECURITY CAMERA RECORDS
  • MAIN PURPOSES OF PROCESSING: ENSURING THE SECURITY OF THE WORKPLACE, EMPLOYEES, VISITORS AND COMPANY ASSETS; CARRYING OUT ENTRY-EXIT AND SECURITY PROCESSES
  • LEGAL BASIS: FULFILLMENT OF LEGAL OBLIGATIONS; LEGITIMATE INTERESTS OF THE COMPANY, PROVIDED THAT THE FUNDAMENTAL RIGHTS AND FREEDOMS OF THE DATA SUBJECT ARE NOT PREJUDICED


  • DATA CATEGORY: TRANSACTION SECURITY AND INFORMATION SYSTEMS USAGE DATA
  • MAIN PERSONAL DATA PROCESSED: CORPORATE USER ACCOUNT AND USERNAME INFORMATION; SYSTEM, APPLICATION AND NETWORK ACCESS RECORDS; LOGIN / LOGOUT INFORMATION; ACCESS DATES AND TIMES; IP ADDRESS, DEVICE AND SYSTEM IDENTIFIERS; AUTHORIZATION AND AUTHENTICATION RECORDS; SENDING / RECEIVING, TIME, ADDRESSING AND SIMILAR TRANSACTION RECORDS RELATING TO CORPORATE E-MAIL AND COMMUNICATION SYSTEMS; TECHNICAL RECORDS RELATING TO THE USE OF CORPORATE DEVICES, SOFTWARE, APPLICATIONS AND INFORMATION SYSTEMS; LOG RECORDS; INFORMATION SECURITY INCIDENT, ALERT, INVESTIGATION AND AUDIT RECORDS; AND, TO THE EXTENT REQUIRED FOR THE PERFORMANCE OF WORK, INFORMATION SECURITY OR LEGAL PROCESSES, CORPORATE COMMUNICATION AND TRANSACTION RECORDS
  • MAIN PURPOSES OF PROCESSING: ESTABLISHMENT AND PERFORMANCE OF THE EMPLOYMENT RELATIONSHIP AND ASSIGNED DUTIES; PROVISION AND OPERATION OF CORPORATE E-MAIL, COMMUNICATION, SOFTWARE, APPLICATION AND INFORMATION SYSTEMS; MANAGEMENT OF USER ACCOUNTS AND ACCESS AUTHORIZATIONS; ENSURING INFORMATION AND SYSTEM SECURITY; PREVENTION AND DETECTION OF UNAUTHORIZED ACCESS AND MISUSE; ENSURING SYSTEM AND APPLICATION CONTINUITY; INVESTIGATION OF ERRORS, MALFUNCTIONS AND INFORMATION SECURITY INCIDENTS; CREATION AND PRESERVATION OF BUSINESS AND TRANSACTION RECORDS; AND CARRYING OUT AUDIT, INTERNAL CONTROL AND, WHERE NECESSARY, LEGAL PROCESSES
  • LEGAL BASIS: PROCESSING BEING DIRECTLY RELATED TO AND NECESSARY FOR THE ESTABLISHMENT OR PERFORMANCE OF A CONTRACT; PROCESSING BEING NECESSARY FOR THE DATA CONTROLLER TO FULFIL ITS LEGAL OBLIGATIONS; PROCESSING BEING NECESSARY FOR THE ESTABLISHMENT, EXERCISE OR PROTECTION OF A RIGHT; PROCESSING BEING NECESSARY FOR THE LEGITIMATE INTERESTS OF THE COMPANY, PROVIDED THAT SUCH PROCESSING DOES NOT PREJUDICE THE FUNDAMENTAL RIGHTS AND FREEDOMS OF THE DATA SUBJECT


Ø DATA CATEGORY: HEALTH INFORMATION (SPECIAL CATEGORY PERSONAL DATA)


  • MAIN PERSONAL DATA OBTAINED: HEALTH REPORTS; PRE-EMPLOYMENT AND PERIODIC HEALTH EXAMINATION REPORTS; BLOOD GROUP; DISABILITY INFORMATION; PREGNANCY/CHILDBIRTH REPORTS AND LEAVE DOCUMENTS; PERSONAL HEALTH INFORMATION; INFORMATION ON DEVICES AND PROSTHESES USED
  • MAIN PURPOSES OF OBTAINING: ASSESSMENT OF FITNESS FOR EMPLOYMENT AND DUTIES; CONDUCTING HEALTH SURVEILLANCE; CARRYING OUT OCCUPATIONAL HEALTH AND SAFETY, PERSONNEL, SOCIAL SECURITY AND EMPLOYEE RIGHTS/BENEFITS PROCESSES
  • LEGAL BASIS: NECESSITY FOR FULFILLING LEGAL OBLIGATIONS IN THE FIELDS OF EMPLOYMENT, OCCUPATIONAL HEALTH AND SAFETY AND SOCIAL SECURITY


  • MAIN PERSONAL DATA RECORDED / RETAINED: HEALTH REPORTS; PERIODIC HEALTH EXAMINATION RECORDS; BLOOD GROUP; DISABILITY INFORMATION; PREGNANCY/CHILDBIRTH REPORTS AND LEAVE DOCUMENTS; RELEVANT HEALTH AND OCCUPATIONAL HEALTH AND SAFETY RECORDS
  • MAIN PURPOSES OF RECORDING / RETENTION: CREATION AND RETENTION OF PERSONNEL AND HEALTH RECORDS; FULFILLING OCCUPATIONAL HEALTH AND SAFETY AND HEALTH SURVEILLANCE OBLIGATIONS; DOCUMENTATION OF REPORT/LEAVE AND EMPLOYEE RIGHTS; FULFILLING STATUTORY RETENTION OBLIGATIONS
  • LEGAL BASIS: NECESSITY FOR FULFILLING LEGAL OBLIGATIONS IN THE FIELDS OF EMPLOYMENT, OCCUPATIONAL HEALTH AND SAFETY AND SOCIAL SECURITY; WHERE NECESSARY, NECESSITY OF DATA PROCESSING FOR THE ESTABLISHMENT, EXERCISE OR PROTECTION OF A RIGHT


  • MAIN PERSONAL DATA USED / EVALUATED: HEALTH REPORTS; FITNESS-FOR-WORK INFORMATION; WORK RESTRICTIONS; PERIODIC HEALTH EXAMINATION RESULTS; DISABILITY AND RELATED HEALTH CONDITION INFORMATION; REPORT AND LEAVE INFORMATION
  • MAIN PURPOSES OF USE / EVALUATION: ASSESSMENT OF FITNESS FOR EMPLOYMENT/DUTIES; DETERMINATION OF OCCUPATIONAL HEALTH AND SAFETY MEASURES; CONDUCTING HEALTH SURVEILLANCE; ARRANGEMENT OF WORKING CONDITIONS; CARRYING OUT REPORT/LEAVE, OCCUPATIONAL ACCIDENT/OCCUPATIONAL DISEASE AND EMPLOYEE RIGHTS/BENEFITS PROCESSES
  • LEGAL BASIS: NECESSITY FOR FULFILLING LEGAL OBLIGATIONS IN THE FIELDS OF EMPLOYMENT, OCCUPATIONAL HEALTH AND SAFETY AND SOCIAL SECURITY; WHERE NECESSARY, NECESSITY OF DATA PROCESSING FOR THE ESTABLISHMENT, EXERCISE OR PROTECTION OF A RIGHT


  • MAIN PERSONAL DATA SHARED / TRANSFERRED: TO THE EXTENT REQUIRED BY THE RELEVANT ACTIVITY, HEALTH REPORT; HEALTH SURVEILLANCE INFORMATION; OCCUPATIONAL ACCIDENT/OCCUPATIONAL DISEASE INFORMATION; REPORT/LEAVE AND OTHER NECESSARY HEALTH INFORMATION
  • MAIN PURPOSES OF SHARING / TRANSFER: PROVISION OF OCCUPATIONAL HEALTH AND SAFETY AND HEALTH SERVICES; FULFILLING SOCIAL SECURITY AND STATUTORY OBLIGATIONS; PROVIDING NECESSARY INFORMATION TO AUTHORIZED PUBLIC INSTITUTIONS AND ORGANIZATIONS AND AUTHORIZED HEALTH/OCCUPATIONAL HEALTH AND SAFETY SERVICE PROVIDERS; ESTABLISHMENT, EXERCISE OR PROTECTION OF LEGAL RIGHTS
  • LEGAL BASIS: NECESSITY FOR FULFILLING LEGAL OBLIGATIONS IN THE FIELDS OF EMPLOYMENT, OCCUPATIONAL HEALTH AND SAFETY AND SOCIAL SECURITY; OTHER CONDITIONS UNDER ARTICLE 6 OF THE KVKK APPLICABLE TO THE RELEVANT ACTIVITY; NECESSITY FOR THE ESTABLISHMENT, EXERCISE OR PROTECTION OF A RIGHT
  • OPTIONAL TRANSFERS OUTSIDE THIS SCOPE ARE ASSESSED SEPARATELY, AND EXPLICIT CONSENT IS OBTAINED IF NO OTHER LEGAL BASIS EXISTS!


Ø DATA CATEGORY: TRADE UNION MEMBERSHIP (SPECIAL CATEGORY PERSONAL DATA)


  • MAIN PERSONAL DATA OBTAINED: TRADE UNION MEMBERSHIP INFORMATION; NAME OF TRADE UNION; MEMBERSHIP / TERMINATION OF MEMBERSHIP STATUS; INFORMATION REQUIRED FOR MEMBERSHIP DUES / SOLIDARITY DUES TRANSACTIONS
  • MAIN PURPOSES OF OBTAINING: CONDUCTING COLLECTIVE LABOUR RELATIONS; CARRYING OUT PROCESSES UNDER THE COLLECTIVE LABOUR AGREEMENT; DETERMINING AND IMPLEMENTING EMPLOYEE RIGHTS AND BENEFITS ASSOCIATED WITH TRADE UNION MEMBERSHIP; CARRYING OUT MEMBERSHIP / SOLIDARITY DUES AND RELATED WAGE/PAYROLL TRANSACTIONS; FULFILLING OBLIGATIONS ARISING FROM EMPLOYMENT AND LABOUR LEGISLATION
  • LEGAL BASIS: EXPRESSLY PROVIDED FOR BY LAW; NECESSITY OF DATA PROCESSING FOR THE ESTABLISHMENT, EXERCISE OR PROTECTION OF A RIGHT; NECESSITY FOR FULFILLING LEGAL OBLIGATIONS IN THE FIELDS OF EMPLOYMENT AND SOCIAL SECURITY


  • MAIN PERSONAL DATA RECORDED / RETAINED: TRADE UNION MEMBERSHIP INFORMATION; RECORDS RELATING TO MEMBERSHIP / TERMINATION OF MEMBERSHIP STATUS; MEMBERSHIP OR SOLIDARITY DUES RECORDS; RECORDS RELATING TO THE IMPLEMENTATION OF THE COLLECTIVE LABOUR AGREEMENT
  • MAIN PURPOSES OF RECORDING / RETENTION: KEEPING RECORDS WITHIN THE SCOPE OF COLLECTIVE LABOUR RELATIONS AND THE COLLECTIVE LABOUR AGREEMENT; DOCUMENTATION OF EMPLOYEE RIGHTS AND BENEFITS; RETENTION OF RECORDS RELATING TO MEMBERSHIP / SOLIDARITY DUES AND WAGE/PAYROLL TRANSACTIONS; FULFILLING OBLIGATIONS ARISING FROM LEGISLATION AND THE EMPLOYMENT RELATIONSHIP; WHERE NECESSARY, PROVING AND PROTECTING LEGAL RIGHTS
  • LEGAL BASIS: EXPRESSLY PROVIDED FOR BY LAW; NECESSITY OF DATA PROCESSING FOR THE ESTABLISHMENT, EXERCISE OR PROTECTION OF A RIGHT; NECESSITY FOR FULFILLING LEGAL OBLIGATIONS IN THE FIELDS OF EMPLOYMENT AND SOCIAL SECURITY


  • MAIN PERSONAL DATA USED / EVALUATED: TRADE UNION MEMBERSHIP AND MEMBERSHIP STATUS INFORMATION; INFORMATION REQUIRED FOR THE IMPLEMENTATION OF RIGHTS AND BENEFITS UNDER THE COLLECTIVE LABOUR AGREEMENT; RELEVANT WAGE/PAYROLL, MEMBERSHIP DUES OR SOLIDARITY DUES TRANSACTION INFORMATION
  • MAIN PURPOSES OF USE / EVALUATION: IMPLEMENTATION OF COLLECTIVE LABOUR AGREEMENT PROVISIONS; CARRYING OUT PROCESSES RELATING TO RIGHTS AND BENEFITS ASSOCIATED WITH EMPLOYEES' TRADE UNION STATUS; PERFORMING MEMBERSHIP / SOLIDARITY DUES DEDUCTION AND PAYMENT TRANSACTIONS; CARRYING OUT PAYROLL AND WAGE PROCESSES; MANAGEMENT OF COLLECTIVE LABOUR RELATIONS AND EMPLOYMENT PROCESSES
  • LEGAL BASIS: EXPRESSLY PROVIDED FOR BY LAW; NECESSITY OF DATA PROCESSING FOR THE ESTABLISHMENT, EXERCISE OR PROTECTION OF A RIGHT; NECESSITY FOR FULFILLING LEGAL OBLIGATIONS IN THE FIELDS OF EMPLOYMENT AND SOCIAL SECURITY


  • MAIN PERSONAL DATA SHARED / TRANSFERRED: PROVIDED THAT IT IS NECESSARY AND PROPORTIONATE FOR THE RELEVANT TRANSACTION, TRADE UNION MEMBERSHIP / MEMBERSHIP STATUS INFORMATION; MEMBERSHIP OR SOLIDARITY DUES INFORMATION; NECESSARY INFORMATION RELATING TO THE IMPLEMENTATION OF THE COLLECTIVE LABOUR AGREEMENT
  • MAIN PURPOSES OF SHARING / TRANSFER: FULFILLING STATUTORY OBLIGATIONS RELATING TO TRADE UNION DUES AND COLLECTIVE LABOUR RELATIONS; SHARING NECESSARY INFORMATION WITH THE AUTHORIZED TRADE UNION, PUBLIC INSTITUTIONS AND ORGANIZATIONS AND JUDICIAL/ADMINISTRATIVE AUTHORITIES; ESTABLISHMENT, EXERCISE OR PROTECTION OF EMPLOYEES' RIGHTS ARISING FROM THE COLLECTIVE LABOUR AGREEMENT AND RELEVANT LEGISLATION
  • LEGAL BASIS: EXPRESSLY PROVIDED FOR BY LAW; NECESSITY OF DATA PROCESSING FOR THE ESTABLISHMENT, EXERCISE OR PROTECTION OF A RIGHT; NECESSITY FOR FULFILLING LEGAL OBLIGATIONS IN THE FIELDS OF EMPLOYMENT AND SOCIAL SECURITY
  • OPTIONAL TRANSFERS OUTSIDE THIS SCOPE ARE ASSESSED SEPARATELY, AND EXPLICIT CONSENT IS OBTAINED IF NO OTHER LEGAL BASIS EXISTS!


Ø DATA CATEGORY: CRIMINAL CONVICTIONS AND SECURITY MEASURES (SPECIAL CATEGORY PERSONAL DATA)


  • MAIN PERSONAL DATA OBTAINED: CRIMINAL RECORD; INFORMATION RELATING TO CRIMINAL CONVICTIONS; INFORMATION RELATING TO SECURITY MEASURES
  • MAIN PURPOSES OF OBTAINING: ASSESSMENT OF LEGAL OR PROFESSIONAL REQUIREMENTS NECESSARY FOR THE DUTY/POSITION; DETERMINATION OF SUITABILITY FOR THE RELEVANT POSITION; FULFILLING EMPLOYMENT CONDITIONS AND OBLIGATIONS ARISING FROM LEGISLATION; PROTECTION OF THE LEGAL RIGHTS OF THE EMPLOYER AND RELEVANT PARTIES
  • LEGAL BASIS: TO THE EXTENT APPLICABLE TO THE SPECIFIC ACTIVITY: EXPRESSLY PROVIDED FOR BY LAW; NECESSITY OF DATA PROCESSING FOR THE ESTABLISHMENT, EXERCISE OR PROTECTION OF A RIGHT; NECESSITY FOR FULFILLING LEGAL OBLIGATIONS IN THE FIELD OF EMPLOYMENT


  • MAIN PERSONAL DATA RECORDED / RETAINED: CRIMINAL RECORD INFORMATION NECESSARY WITH REGARD TO THE RELEVANT POSITION OR LEGAL REQUIREMENT; NECESSARY RECORDS RELATING TO CRIMINAL CONVICTIONS; NECESSARY RECORDS RELATING TO SECURITY MEASURES
  • MAIN PURPOSES OF RECORDING / RETENTION: DOCUMENTATION THAT THE LEGAL AND PROFESSIONAL REQUIREMENTS RELATING TO THE POSITION HAVE BEEN FULFILLED; KEEPING NECESSARY RECORDS RELATING TO THE EMPLOYMENT PROCESS; FULFILLING STATUTORY RECORD-KEEPING AND RETENTION OBLIGATIONS; WHERE NECESSARY, ESTABLISHMENT, EXERCISE OR PROTECTION OF LEGAL RIGHTS
  • LEGAL BASIS: TO THE EXTENT APPLICABLE TO THE SPECIFIC ACTIVITY: EXPRESSLY PROVIDED FOR BY LAW; NECESSITY OF DATA PROCESSING FOR THE ESTABLISHMENT, EXERCISE OR PROTECTION OF A RIGHT; NECESSITY FOR FULFILLING LEGAL OBLIGATIONS IN THE FIELD OF EMPLOYMENT


  • MAIN PERSONAL DATA USED / EVALUATED: NECESSARY INFORMATION RELATING TO CRIMINAL RECORD STATUS; RELEVANT CRIMINAL CONVICTION OR SECURITY MEASURE INFORMATION; INFORMATION REQUIRED FOR ASSESSING THE LEGAL OR PROFESSIONAL QUALIFICATION REQUIREMENTS PRESCRIBED FOR THE POSITION
  • MAIN PURPOSES OF USE / EVALUATION: ASSESSMENT OF LEGAL OR PROFESSIONAL REQUIREMENTS RELATING TO THE PERFORMANCE OF THE RELEVANT DUTY; DETERMINATION AND CONTINUATION OF SUITABILITY FOR THE DUTY/POSITION; FULFILLING LEGAL OBLIGATIONS ARISING FROM EMPLOYMENT; CARRYING OUT PROCESSES RELATING TO LEGAL DISPUTES AND THE ESTABLISHMENT, EXERCISE OR PROTECTION OF RIGHTS
  • LEGAL BASIS: TO THE EXTENT APPLICABLE TO THE SPECIFIC ACTIVITY: EXPRESSLY PROVIDED FOR BY LAW; NECESSITY OF DATA PROCESSING FOR THE ESTABLISHMENT, EXERCISE OR PROTECTION OF A RIGHT; NECESSITY FOR FULFILLING LEGAL OBLIGATIONS IN THE FIELD OF EMPLOYMENT


  • MAIN PERSONAL DATA SHARED / TRANSFERRED: TO THE EXTENT REQUIRED BY THE RELEVANT TRANSACTION, CRIMINAL RECORD INFORMATION; CRIMINAL CONVICTION INFORMATION; INFORMATION RELATING TO SECURITY MEASURES
  • MAIN PURPOSES OF SHARING / TRANSFER: PROVIDING NECESSARY INFORMATION TO PUBLIC INSTITUTIONS AND ORGANIZATIONS AUTHORIZED BY LAW; COMPLYING WITH REQUESTS OF AUTHORIZED JUDICIAL OR ADMINISTRATIVE AUTHORITIES; FULFILLING OBLIGATIONS ARISING FROM LEGISLATION; CARRYING OUT NECESSARY LEGAL PROCESSES FOR THE ESTABLISHMENT, EXERCISE OR PROTECTION OF A RIGHT
  • LEGAL BASIS: TO THE EXTENT APPLICABLE TO THE SPECIFIC ACTIVITY: EXPRESSLY PROVIDED FOR BY LAW; NECESSITY OF DATA PROCESSING FOR THE ESTABLISHMENT, EXERCISE OR PROTECTION OF A RIGHT; NECESSITY FOR FULFILLING LEGAL OBLIGATIONS IN THE FIELD OF EMPLOYMENT
  • OPTIONAL TRANSFERS OUTSIDE THIS SCOPE ARE ASSESSED SEPARATELY, AND EXPLICIT CONSENT IS OBTAINED IF NO OTHER LEGAL BASIS EXISTS!


Data processing activities based on explicit consent are carried out under the relevant explicit consent texts separately issued from this Information Notice. Separate explicit consent is not requested for activities for which a legal processing condition other than explicit consent exists. Activities requiring explicit consent in relation to employees’ voluntary visual/audio recordings that may be used for corporate communication, promotion, events or similar purposes are separately assessed under the “Explicit Consent Text for Visual and Audio Recordings”. Detailed information on image processing carried out through security cameras is available in the COMPANY'S website under the Camera Information Notice.


3. METHODS OF COLLECTING PERSONAL DATA

Employees’ personal data may be collected during the establishment of the employment relationship, throughout the employment relationship and in processes relating to its termination…

  • Documents, forms, contracts, petitions and declarations submitted by the employee
  • Personnel and human resources records
  • Corporate records maintained in physical and/or electronic form
  • Corporate e-mail, KEP, telephone and other communication channels
  • Records and forms completed via the internet or corporate systems
  • Payroll, salary, leave, training, timekeeping, expense and similar employment records
  • Security and entry-exit systems and security cameras
  • Information and documents lawfully obtained from authorized public institutions and organizations
  • Other corporate systems and records used within the scope of duties and activities

 …by wholly or partly automated means or by non-automated means, provided that they form part of a data recording system may be collected.

Where personal data is not obtained directly from the employee, the information principles prescribed under the KVKK and the relevant legislation are also applied. COMPANY does not seek to obtain special category personal data that is not required by the employment relationship and the related legal/operational processes and adopts the principle that unnecessary special category personal data shall not be requested or processed.


4. TRANSFER OF PERSONAL DATA

Employees’ personal data may, strictly to the extent required by the relevant processing purpose and legal necessity, be shared with the Social Security Institution (SGK), İŞKUR, the Ministry of Labour and Social Security, the Ministry of Treasury and Finance, banks, authorized service providers within the scope of occupational health and safety/health services, judicial and administrative authorities, enforcement offices, law enforcement units, and other public institutions and organizations authorized by legislation to receive information, to the extent required by the relevant data processing activity.

 

Personal data may also, depending on the nature of the relevant activity;

  • Employees and officers authorized by the COMPANY and subject to confidentiality/data security obligations,
  • Service providers carrying out certain personal data processing activities on behalf of the COMPANY - for example, security system providers, financial or legal advisers and data processing service providers,
  • For the fulfilment of legal obligations or the establishment, exercise or protection of a right, it may be shared with authorized judicial/administrative authorities and law enforcement units .

 

TRANSFER ABROAD: According to the COMPANY'S current “Personal Data Processing Inventory”, there is no transfer abroad of the employee personal data covered by this “Employee Information Notice”. If, in the future, a new data processing activity arises that requires employee personal data to be transferred abroad, the necessary legal and technical assessments shall be carried out before the relevant transfer activity begins, in accordance with Article 9 of the KVKK and the relevant legislation; the necessary information and document updates shall also be made.


5. RETENTION AND DESTRUCTION OF PERSONAL DATA

Employees’ personal data is retained for the periods prescribed by the relevant legislation and for as long as the purposes requiring the processing of personal data continue, in accordance with the periods specified in the COMPANY'S “Personal Data Processing Inventory” and “Personal Data Retention and Destruction Policy”.

Under the current Inventory, the principal retention periods are; for employee personnel and employment relationship records 10 years from the termination of the employment relationship; for health reports and periodic health records, 15 years from the termination of the employment relationship; for security camera recordings under ordinary conditions from the date of recording 15 days; for records relating to legal relationships based on certain contracts 10 years and for certain litigation/dispute records from the end of the litigation or dispute 5 years have been determined.

Pursuant to Article 7 of the KVKK, where the reasons requiring the processing of personal data cease to exist, even though the data has been processed in accordance with the relevant legislation, the personal data is deleted, destroyed or anonymized ex officio or at the request of the data subject in accordance with the COMPANY'S “Personal Data Retention and Destruction Policy”.


6. SECURITY OF PERSONAL DATA AND MEASURES TAKEN

Pursuant to Article 12 of the KVKK, the COMPANY takes the necessary administrative and technical measures to prevent unlawful processing of and unlawful access to personal data, ensure the secure retention of personal data and maintain an appropriate level of security.

Within this scope, measures include the creation and updating of the personal data processing inventory, the establishment and implementation of corporate policies and procedures, contractual regulation of confidentiality and data security obligations, employee training and awareness activities, access and authorization management, revocation of authorizations in the event of role changes or termination of employment, logging, firewalls, protection against malware, backups, appropriate encryption measures, security and penetration tests, additional security measures for special category personal data, periodic controls, breach notification mechanisms, and network and application security measures.

In the event of a personal data breach, the COMPANY fulfils its obligations under the KVKK and the relevant decisions of the Personal Data Protection Board.


7. 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

 

8. 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.


9. 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


10. UPDATES TO THIS NOTICE

This “Employee Information Notice” may be updated in line with changes in legislation, decisions of the Personal Data Protection Board, COMPANY'S personal data processing activities or other legal and operational requirements. The current version of this Notice is published in the COMPANY'S website under the KVKK section. Where a change in personal data processing activities requires separate notification to data subjects, the necessary information shall additionally be provided in accordance with the KVKK and the relevant legislation.