Public Announcement of the Personal Data Protection Authority on the Use of Security Camera Systems in Apartment Buildings

On 8 June 2026, the Turkish Personal Data Protection Authority (Authority) published its “Public Announcement on Matters to Be Considered in the Use of Security Camera Systems in Apartment Buildings”, clarifying the fundamental principles and obligations applicable to personal data processing activities carried out through security camera systems used in apartment buildings and residential complexes.

The announcement states that security camera systems may be used for purposes such as ensuring general security in apartment buildings or residential complexes, protecting the main property, safeguarding common areas, and preventing crimes such as theft or damage to property. However, the Authority emphasizes that such activities must be conducted in compliance with the Personal Data Protection Law No. 6698 (KVKK) and the Condominium Law No. 634.

The key points highlighted by the Authority are as follows:

• Recording images through security cameras constitutes a personal data processing activity. Therefore, the use of camera systems must be based on one of the data processing conditions set out under the KVKK.
• Security camera systems may be installed in common areas of apartment buildings and residential complexes for legitimate purposes such as protecting common areas, ensuring security, and safeguarding the interests of condominium owners. Nevertheless, decisions regarding such installations must be evaluated within the framework of the Condominium Law.
• When determining camera placement, the reasonable expectations of privacy of residents must be taken into account. Cameras should not be positioned in a manner that allows monitoring of apartment entrances, stairwells, or the interiors of independent units.
• Camera systems should be equipped only with technical features that are relevant, necessary, and proportionate to the intended purpose. Features that constitute a greater intrusion into privacy, such as facial recognition and audio recording, should be avoided. Cameras should record with the narrowest possible angle, and unnecessary areas should be masked.
• Although elevators qualify as common areas, their confined and enclosed nature may create an intensive surveillance effect on individuals. Therefore, where cameras are installed in elevators, the necessity for such installation should be demonstrated clearly and concretely.
• Appropriate technical and administrative measures must be implemented to ensure the security of camera recordings. Unauthorized access and disclosures must be prevented, and recordings should be retained only for as long as necessary. Records whose retention period has expired or whose processing purpose no longer exists must be deleted, destroyed, or anonymized. In the event of an incident, only the relevant recordings should be retained for the duration of the applicable legal proceedings.
• Individuals must be clearly informed that camera recording is taking place, and the information obligation under the KVKK must be fulfilled.

The announcement further notes that, where a violation of obligations arising from the KVKK is identified, administrative fines may be imposed on data controllers pursuant to Article 18 of the KVKK.