It is forbidden to copy, reproduce, use, publish and distribute all content contained in this Policy text, in whole or in part, without permission, except for individual use. Legal action will be taken against those who do not comply with this prohibition in accordance with the Law No. 5846 on Intellectual and Artistic Works. All rights of the product are reserved.
Personal Data Storage and Destruction Policy (“Policy”) has been prepared in line with the decisions of the Personal Data Protection Board and the Personal Data Protection Law No. 6098 in order to determine the procedures and principles regarding the works and transactions regarding the storage and destruction activities carried out by “Karayel Arge Dış Ticaret Hizmetleri” (“Karayel Arge” or “Institution”). The Company has prioritized the processing of personal data belonging to its employees, employee candidates, suppliers, service providers, visitors and other third parties in accordance with the Constitution of the Republic of Turkey, international conventions, the Law No. 6698 on the Protection of Personal Data (“Law”) and other relevant legislation and ensuring that the relevant persons effectively exercise their rights.
The works and transactions regarding the storage and destruction of personal data are carried out in accordance with the Policy prepared by the Company in this direction.
Personal data belonging to Company employees, employee candidates, service providers, visitors and other third parties are within the scope of this Policy and this Policy is applied in all recording environments where personal data owned or managed by the Company are processed and in activities for personal data processing.
Open Consent |
Consent on a specific issue, based on information and freely given. |
Buyer Group |
The category of natural or legal person to whom personal data is transferred by the data controller. |
Anonymization |
Making personal data impossible to be associated with an identified or identifiable natural person under any circumstances, even by matching with other data. |
Employee/Staff/Laborer |
An employee of Karayel Arge Foreign Trade Services under the supervision and control of Karayel Arge Foreign Trade Services within the scope of insurance and labor contract. |
EBYS |
Electronic Document Management System |
Electronic Media |
Environments where personal data can be created, read, modified and written with electronic devices. |
Non-Electronic Environment |
All written, printed, visual, etc. media other than electronic media. |
Service Provider |
A natural or legal person who provides services under a specific contract with Karayel Arge Foreign Trade Services.
|
Contact Person |
The natural person whose personal data is processed. |
Related User |
Persons who process personal data within the organization of the data controller or in accordance with the authorization and instruction received from the data controller, except for the person or unit responsible for the technical storage, protection and backup of the data. |
Destruction |
Deletion, destruction or anonymization of personal data. |
Law |
Law No. 6698 on the Protection of Personal Data. |
Kayıt Ortamı |
Tamamen veya kısmen otomatik olan ya da herhangi bir veri kayıt sisteminin parçası olmak kaydıyla otomatik olmayan yollarla işlenen kişisel verilerin bulunduğu her türlü ortam. |
Personal Data |
Any information relating to an identified or identifiable natural person. |
Personal Data Processing Inventory |
Inventory in which data controllers detail the personal data processing activities they carry out depending on their business processes by associating them with the purposes of processing personal data, the data category, the group of recipients transferred and the group of data subjects, and by explaining the maximum period required for the purposes for which personal data are processed, the personal data envisaged to be transferred to foreign countries and the measures taken regarding data security. |
Processing of Personal Data |
Any operation performed on personal data such as obtaining, recording, storing, storing, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automatic means or by non-automatic means provided that it is part of any data recording system. |
Board |
Personal Data Protection Board |
Sensitive Personal Data |
Data on race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data. |
Periodic Disposal |
Deletion, destruction or anonymization to be carried out ex officio at recurring intervals specified in the personal data retention and destruction policy in the event that all of the conditions for processing personal data specified in the law disappear. |
Politics |
Personal Data Retention and Destruction Policy. |
Data Processor |
A natural or legal person who processes personal data on behalf of the data controller based on the authorization granted by the data controller. |
Data Recording System |
A recording system where personal data is structured and processed according to certain criteria. |
Data Controller |
The natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system. |
Data Controllers Registry Information System |
The information system created and managed by the Presidency of the Data Protection Board, accessible via the internet, which data controllers will use in the application to the Registry and other related transactions regarding the Registry. |
VERBIS |
Data Controllers Registry Information System. |
Regulation |
Regulation on Deletion, Destruction or Anonymization of Personal Data published in the Official Gazette dated October 28, 2017. |
All units and employees of the Company actively support the responsible units in taking technical and administrative measures to ensure data security in all environments where personal data is processed in order to prevent unlawful processing of personal data, to prevent unlawful access to personal data and to ensure that personal data is stored in accordance with the law, with the proper implementation of the administrative and technical measures taken by the responsible units within the scope of the Policy, training and awareness of the unit employees, monitoring and continuous supervision. In cases where it is not possible to employ within the Company, the Company provides such support through service providers.
Title |
Job Description |
In the projects carried out in the process of compliance with the Law, it is obliged to carry out / have carried out / direct all kinds of planning, analysis, research, risk identification studies; to manage the processes to be carried out in accordance with the Law, Personal Data Processing and Protection Policy and Personal Data Storage and Destruction Policy and to resolve the requests received by the relevant persons. The Authority provides legal support in this regard through service providers.
|
|
KVK Legal Compliance Specialist |
It is responsible for examining the requests of the data subjects and reporting them to the Personal Data Committee Manager for evaluation; fulfillment of the transactions regarding the requests of the data subjects evaluated and decided by the Personal Data Committee Manager in accordance with the decision of the Personal Data Committee Manager; legal compliance regarding storage and destruction processes; and the Personal Data Unit Manager and the PDP Technical and Administrative Implementation Specialist to act in accordance with the Law. The Authority provides legal support in this regard through service providers.
|
KVK Technical and Administrative Application Specialist |
It is responsible for auditing the storage and destruction processes and reporting these audits to the Personal Data Committee Manager; conducting technical and administrative audits in accordance with the instructions of the KVK Legal Compliance Specialist regarding legal compliance; and carrying out the storage and destruction processes. The Authority provides technical support in this regard through service providers. |
Personal data is securely stored by the Company in accordance with the law in the environments listed in Table 2.
3.1. AUTOMATED DATA STORAGE METHODS |
|
|
|
|
|
|
|
|
|
|
|
|
|
3.2. PHYSICAL RECORDING METHOD |
Archive, Physical Recording, Manual Recording
Personal data belonging to employees, employee candidates, visitors and employees of third parties, institutions or organizations with whom the Company has a relationship as a service provider are stored and destroyed in accordance with the Law.
In this context, detailed explanations on retention and destruction are given below respectively:
Article 3 of the Law defines the concept of “Processing of Personal Data”, Article 4 states that the personal data processed must be relevant, limited and proportionate to the purpose for which they are processed and must be retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed, and Articles 5 and 6 list the conditions for processing personal data.
Accordingly, within the framework of the Company's activities, personal data are stored for the period stipulated in the relevant legislation or in accordance with our processing purposes.
Personal data processed within the framework of the Company's activities are retained for the period stipulated in the relevant legislation. In this context, personal data;
The Company stores the personal data it processes within the framework of its activities for the following purposes.
Personal data;
Technical and administrative measures are taken by the Company within the framework of adequate measures determined and announced by the Board for special categories of personal data in accordance with Article 12 of the Law and Article 6, paragraph four of the Law for the safe storage of personal data, prevention of unlawful processing and access and destruction of personal data in accordance with the law.
The technical measures taken by the Company regarding the personal data it processes are listed below:
The administrative measures taken by the Company regarding the personal data it processes are listed below:
At the end of the period stipulated in the relevant legislation or at the end of the retention period required for the purpose for which they are processed, personal data shall be destroyed by the Company ex officio or upon the application of the person concerned by the following techniques in accordance with the provisions of the relevant legislation.
Personal Data on Servers |
For the personal data on the servers, deletion is made by the system administrator by removing the access authorization of the relevant users for those whose retention period has expired. |
Personal Data in Electronic Media | The personal data stored in electronic media that expire after the period of time required for their retention are rendered inaccessible and non-reusable in any way for employees (relevant users) other than the database administrator. |
Personal Data in Physical Environment | For the personal data kept in physical environment, those whose period of storage has expired are rendered inaccessible and non-reusable in any way for employees other than the unit manager responsible for the document archive. In addition, the blackout process is also applied by scratching/painting/erasing in such a way that it cannot be read. |
Personal Data on Portable Media | The personal data kept in Flash-based storage media and those whose retention period has expired are encrypted by the system administrator and access authorization is given only to the system administrator and stored in secure environments with encryption keys. |
Personal Data in Physical Environment | The personal data on paper media that expire after the expiration of the retention period are irreversibly destroyed in paper shredding machines. |
Personal Data on Optical / Magnetic Media, Portable Media | The personal data contained in optical media and magnetic media that expire after the period of time required to be retained is first destroyed in a way that cannot be physically reassembled, such as deletion, melting, incineration or pulverization. |
Anonymization of personal data is the process of making personal data impossible to associate with an identified or identifiable natural person under any circumstances, even if the personal data is matched with other data.
In order for personal data to be anonymized, personal data must be rendered unrelated to an identified or identifiable natural person, even through the use of techniques appropriate for the recording medium and the relevant field of activity, such as the reversal of personal data by the data controller or third parties and/or the matching of data with other data. Therefore, in practice, data sets are rendered “irreversible” through the methods of “obfuscation”, “de-identification”, “interruption and prevention of connection with the person” used for the anonymization of personal data. With the anonymization of the data, the Company prevents access to the data of the real person with one or more information.
Regarding the personal data processed by the Company within the scope of the Company's activities;
Board Operations |
10 year |
At the first periodic destruction following the end of the storage period |
Preparation of contracts | 10 years following the end of the contract | At the first periodic destruction following the end of the storage period |
Execution of Company Communication Activities | 10 years after the end of the activity | At the first periodic destruction following the end of the storage period |
Human Resources Processes | 10 years after the end of the activity | At the first periodic destruction following the end of the storage period |
Log Recording Tracking Systems |
10 year |
At the first periodic destruction following the end of the storage period
|
Execution of Hardware and Software Access Processes |
2 year |
At the first periodic destruction following the end of the storage period
|
Registration of Visitors and Meeting Participants |
2 years following the end of the event
|
At the first periodic destruction following the end of the storage period |
Camera Recordings |
27 day |
Automatically at the end of the storage period and at the first subsequent periodic disposal period
|
Pursuant to Article 11 of the Regulation on Deletion, Destruction or Anonymization of Personal Data, the Company has determined the periodic destruction period as 6 months. Accordingly, the Company performs periodic destruction in December of the year in which it registers to the Data Controllers Registry Information System (VERBIS), and in June and December of each subsequent year.
The Policy is published in two different media, wet signed (printed paper) and electronic media, and disclosed to the public on the website. Everyone has the right to obtain information on how their data is processed, stored, security measures and destruction policies within the limits stipulated by the Law. In this way, all groups of persons receiving services from our Company can access our Company's “Data Processing Policy” and “Data Storage and Destruction Policy”. The printed paper copy is also kept under record in the Company's Archive Documentation System.
The Policy is reviewed at regular intervals and the necessary sections are updated in line with the decisions of the Data Protection Board and to ensure data security.
The Policy shall be deemed to have entered into force upon its publication on the Company's website. In the event that the Company decides to amend, update or repeal the Policy, the old wet-signed copies of the Policy shall be signed by the Company by stamping or writing cancellation.
The Application to the Data Controller is kept under record in the Company's Archive Documentation System for at least 5 (five) years in order to be submitted in case of audit, request or investigation by the Data Protection Board.
Approved by: (Lawyer) |
Preparation Date: 24.05.2025 |
Revision Date: 01.06.2024 |
|
Bu sitede çerezler kullanılmaktadır. Sitede gezinmeye devam ederek çerezlerimizin kullanımını kabul etmiş olursunuz. Daha Fazla Bilgi
Sosyal Ağ