REGARDING THE PROTECTION OF PERSONAL DATA
COVID-19 PANDEMIC PROCESS CLARIFICATION TEXT
Data Controller: Çağdaş Kağıt Ambalaj San. ve Tic. Ltd. Şti. (Address: Hadımköy Mahallesi İbni Sina Caddesi No:8/5 ARNAVUTKÖY/ISTANBUL Tel: 0212 674 16 25 Website: www.cagdaskagit.com, E-mail: [email protected] Mersis No: 0217038013300019) has prepared and announced this clarification text in accordance with the Personal Data Protection Law No. 6698 (hereinafter referred to as "KVKK") and the Regulation on Procedures and Principles Regarding the Fulfillment of the Obligation of Clarification (hereinafter referred to as "Regulation") to inform the relevant individuals regarding the processing of their personal data during the COVID-19 pandemic period and the procedures and principles to be followed in protecting their personal data during their relationship with our institution.
KVKK Article 10: "At the time of obtaining personal data, the data controller or the person authorized by the data controller is obliged to inform the data subjects regarding the identity of the data controller and its representative, the purposes for which the personal data will be processed, to whom and for what purpose the processed personal data may be transferred, the method and legal basis of personal data collection, and the other rights listed in Article 11."
KEY DEFINITIONS IN THE LAW
Personal Data: Any information relating to an identified or identifiable natural person.
Processing of Personal Data: Any operation performed on personal data, such as collection, recording, storage, maintenance, alteration, rearrangement, disclosure, transfer, acquisition, retrieval, classification, or preventing its use, by automated or non-automated means as part of any data recording system.
Data Controller: The real or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system. In this context, the data controller is Çağdaş Kağıt Ambalaj San. ve Tic. Ltd. Şti., located at Hadımköy Mahallesi İbni Sina Caddesi No:8/5 ARNAVUTKÖY/ISTANBUL.
Data Record System (VERBIS): The system in which personal data is processed and structured according to certain criteria.
Explicit Consent: Consent that is informed and freely given for a specific purpose.
The Board: Refers to the Personal Data Protection Board.
PROCESSED PERSONAL DATA
Our institution may process the personal data of the relevant individuals in line with the purposes and processing conditions specified in this text. The personal data subject to processing include:
Accommodation and Travel information.
Body temperature measurements, Chronic illness information, HES code details and content, COVID-19 symptoms.
METHOD AND LEGAL BASIS FOR COLLECTING PERSONAL DATA
Personal data is collected directly from the relevant individuals and legal authorities during the establishment of legal relationships in the context of the COVID-19 pandemic. Personal data may be collected through body temperature measurement devices, e-mails, electronic devices, and verbal, written, or electronic communication channels, ensuring compliance with public health measures.
In accordance with Article 5 of the KVKK, personal data cannot be processed without the explicit consent of the data subject. The law specifies exceptions where explicit consent is not required. If there is a clear provision in the law, if it is directly related to the establishment or performance of a contract, if it is necessary to process personal data of the parties to the contract, if it is mandatory to fulfill the legal obligation of the company, if the data has been made public by the data subject themselves, if processing the data is necessary for the establishment, use, or protection of a right, or if it is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject, personal data may be processed by our company without the explicit consent of the data subject.
ÇAĞDAŞ KAĞIT AMBALAJ SAN. VE TİC. LTD. ŞTİ.'S PURPOSE FOR PROCESSING PERSONAL DATA
In accordance with Article 10 of the KVKK and Article 5 of the Regulation, personal data of job candidates can be processed for the following purposes in compliance with the processing conditions specified in Article 4 of the KVKK:
WHO PERSONAL DATA CAN BE TRANSFERRED TO AND FOR WHAT PURPOSES
Personal data of data subjects may be transferred to shareholders, private legal entities providing services (security, health - hospitals, occupational safety, legal issues), and authorized public institutions and organizations in accordance with the data transfer and processing conditions specified in Articles 8 and 9 of the Law, in order to achieve the objectives listed above, in compliance with the legal provisions and regulations, and with sufficient and effective measures taken to ensure security and confidentiality.
STORAGE PERIOD OF PERSONAL DATA
In accordance with the provisions of the KVKK, personal data processed for the purposes stated in this "Clarification Text on the Processing of Personal Data" will be deleted, destroyed, or anonymized when the purpose of processing ceases to exist (when the Covid-19 pandemic ends) and/or when the time limits for processing your data as required by legislation expire, in accordance with Article 7/1 of the KVKK.
RIGHTS OF THE DATA SUBJECT
The data subject has the right to learn whether their personal data is processed, to request information about their personal data if it has been processed, to learn the purpose of processing personal data and whether it is used in accordance with its purpose, to know the third parties to whom personal data is transferred both domestically and abroad, to request the correction of personal data if it is inaccurate or incomplete, to request the deletion or destruction of personal data when the reasons for processing no longer exist, to request the notification of the correction, deletion, or destruction of personal data to third parties to whom the data has been transferred, to object to the results that arise from the automated processing of personal data, and to request compensation for damages in case of unlawful processing of personal data that causes harm.
EXCEPTIONS TO THE RIGHT TO APPLY
In accordance with Article 28/2 of the KVKK, data subjects will not be able to exercise the rights specified in Article 11 of the KVKK, except for the right to request compensation for damages, in the following circumstances:
APPLICATION METHOD AND FORM
The data subject can submit their applications regarding the rights mentioned above to the Data Controller in accordance with the application procedures set forth in the Notification on Procedures and Principles for Application to the Data Controller.
Requests within the scope of the rights specified in Article 11 of the Personal Data Protection Law No. 6698 can be made through filling the form available at www.cagdaskagit.com/kvkk and by using one of the methods explained below, in accordance with Article 13 of the KVKK and Article 5 of the Notification on Procedures and Principles for Application to the Data Controller.
Applications submitted to the company will be responded to within 30 days from the date the request is received, depending on the nature of the request, in accordance with Article 13/2 of KVKK. Responses to the application will be delivered to the applicant either in writing or electronically in accordance with Article 13 of the KVKK.
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APPLICATION METHOD |
APPLICATION ADDRESS |
INFORMATION TO BE INCLUDED IN THE APPLICATION |
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1. Written Application |
In-person application with a wet signature or via Notary |
Hadımköy Mahallesi İbni Sina Caddesi No:8/5 ARNAVUTKÖY/ISTANBUL |
The envelope/notices should be marked with "Personal Data Protection Law Information Request". |
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2. Application by Registered Electronic Mail (KEP) |
By Registered Electronic Mail (KEP) |
The subject line of the email should state "Personal Data Protection Law Information Request". |
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3. Application via the Electronic Mail Address in the Company System |
By using the email address registered in the system of Çağdaş Kağıt Ambalaj San. ve Tic. Ltd. Şti. |
The subject line of the email should state "Personal Data Protection Law Information Request". |
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4. Application via the Electronic Mail Address Not in the Company System |
By using an email address not in the system of Çağdaş Kağıt Ambalaj San. ve Tic. Ltd. Şti., including a mobile signature/e-signature |
The subject line of the email should state "Personal Data Protection Law Information Request". |
If the request is accepted or rejected with an explanation of the reasons, the response will be communicated to the applicant either electronically or in writing. If the request is accepted, the company will take immediate action as required.
NOTIFICATION ON PROCEDURES AND PRINCIPLES FOR APPLICATION TO THE DATA CONTROLLER MD. 7
FEE: If the response to the application is provided in writing, no fee will be charged for up to 10 pages, but a processing fee of 1 Turkish Lira may be charged for each page beyond 10 pages. If the response to the application is provided in a recording medium such as a CD or flash drive, a fee equal to the cost of the recording medium may be charged.
