A “Public Announcement on Covid-19 PCR Test Result and Vaccine Information Applications” has been published by Personal Data Protection Board on 28.09.2021.

In summary, the announcement states the following:

  • Article 28/1/ç of the Personal Data Protection Law (“Law”) states that “the provisions of the Law shall not be applied in the following cases where personal data are processed within the scope of preventive, protective and intelligence activities carried out by public institutions and organizations duly authorized and assigned by law to maintain national defence, national security, public security, public order or economic security.”
  • In the light of the above, with regards to processing of personal data re. Covid-19 vaccine information and/or PCR test information:
  • If it is processed within the scope of preventive and protective activities carried out by public institutions and organizations* (in accordance with the above-mentioned provision), the provisions of the Law will not be applied,


• processing of Covid-19 vaccine information and/or negative PCR test information of people who want to participate in activities such as concerts, cinemas, theatres and public transportation vehicles,

• processing of such data by employers who will request employees (who are not vaccinated) to get PCR tests (at employer’s discretion) once a week and storing such test results.

  • If they are processed other than the above (or exceeding the activities for the purpose of protecting public security and public order carried out within the scope of the Covid-19 epidemic) will be subject to provisions of the Law.
Batuhan Şahmay
Partner | [email protected]
Gürkan Çetin
Associate | [email protected]