Principle Decision on The Personal Data Of Third Parties’, Sent By Data Controllers, To The Communication Channels Of The Persons

In accordance with the decision of the Personal Data Protection Authority dated 15.01.2021 and numbered 2020/966, published in the Official Gazette dated 22.12.2020 and numbered 31365; It has been decided that measures should be taken in case the phone number and/or e-mail addresses requested from the relevant person for sending documents containing personal data such as invoices, statements, reservation information are incorrect.

According to Article 4 of the Law on the Protection of Personal Data numbered 6698,  it is stipulated that personal data can be processed in accordance with the procedures and principles stipulated in this law and other laws. In the same article, the principles to be followed in the processing of personal data are listed. One of these principles is to keep personal data accurate and, up to date, when necessary. The measure to be taken according to this principle is explained in the decision of the Board as follows:

“Keeping the personal data included among these principles in an accurate and when necessary up-to-date manner is not only in the interest of the data controller but also necessary for the protection of the fundamental rights and freedoms of the data subject. Therefore the data controller has an attention obligation. Otherwise, people may suffer material and moral damage due to out-of-date or incorrect personal data. For this reason, it is necessary to take measures to verify the contact information declared by the relevant persons. (sending verification code/link to phone number and/or e-mail address, etc.).

It was decided to take administrative and technical measures to establish various mechanisms in order to verify the accuracy of the contact information provided to them in terms of data controllers (for example, sending verification codes to received contact addresses).

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