THE DECISION REGARDING SHARING PERSONAL DATA OF RESEARCH ASSISTANT/ACADEMIC STAFF ON THE WEBSITE WITHOUT THEIR CONSENT

06 February 2020

The Turkish Data Protection Authority (the Authority) published the decision numbered 2019/389, dated 26/12/2019 on the website, 31.01.2020 about the practice of sharing information requested from research assistant and academic staff for appointment of their position.

In the decision, the Authority examined whether the fact that the assessment grade in line with by-law about the procedures and principles for entrance test in the appointment made for the academic positions apart from academic member position (“by-law), is shared to the public via website by the data controller (university), is compliance with the Personal Data Protection Law( “the Law”).

According to the examination, the Authority held that

  1. The assessment grades shall be published in the way that the data should be seen/checked only by the data owner with ID confirmation,
  2. The relation between related persons and assessment grades shall be removed in masking system in which there is no possibility to access to the data subject,
  3. In this context, the information at issue can be published in way that only data subject can understand whose data is as making the letter or number like) “A**** B**** or 11*******11”) mentioned above.         
  4. In the context of obligation to inform, the data subjects have to be informed by the universities regarding the data at issue.

You can find the full text of the decision (in Turkish) here.

Should you have any queries and/or remarks, please do not hesitate to contact us. 

Kind regards,

Zumbul Attorneys-at-Law

info@zumbul.av.tr