Turkiye: Personal Data Protection Authority adopted guide on processing of special personal data

On 26 February 2025, the Personal Data Protection Authority of Turkey adopted the guide on processing special categories of personal data. The guide clarifies legal requirements and compliance following amendments to the Law on Protection of Personal Data. The guide outlines conditions for processing special categories of personal data, reinforcing the principles of legality, accuracy, purpose limitation, proportionality, and retention limits. It clarifies that processing is generally prohibited unless justified under specific legal bases, including explicit consent, legal stipulation, necessity for life protection, public health, or legal rights protection. It provides information on assessing the necessity of processing, requiring justification based on objective evidence. Additionally, it maintains a fixed list of protected data categories, excluding nationality, while emphasising safeguards against discrimination in line with European Court of Human Rights rulings.