KVKK and Personal Data Classification

Use the law's categories without assuming a detection method

Law No. 6698 distinguishes personal data and special categories of personal data. Article 6 covers areas including health, biometric and genetic data, beliefs, certain memberships, and criminal convictions and security measures. The amended law sets conditions for processing these categories. An identifier-only scan cannot be assumed to find every category.

Sources: [1]

Review the amended processing and transfer rules

The 2024 amendments changed Articles 6 and 9, with the main changes effective from 1 June 2024 and a transitional provision for the former transfer rule. Use the amended law when evaluating a processing basis or an international transfer. A data classification label does not establish that a transfer is permitted.

Sources: [1] [2]

Classify by process, purpose and access need

Begin with a defined process such as recruitment, payroll or customer onboarding. List the expected documents, approved locations, access groups and recipients. Test classification with representative examples and ask the process owner to resolve ambiguous findings.

Create handling rules that explain what employees should do. An HR document may need a restricted recipient group and an approved sharing route. Avoid treating all records containing a name as equally sensitive, and avoid treating unrecognised records as automatically safe. These are practical programme design suggestions.

Make monitoring proportionate and transparent

The Board's September 2026 workplace communications decision distinguishes technical access from lawful access. It addresses prior information, the purpose and scope of monitoring, and proportionality. Ownership of a work account or device does not give an employer unlimited inspection rights.

Before enabling content inspection, agree the purpose, permitted access, evidence retention and employee information with the responsible teams. Limit incident access to what the review requires and consider whether a less intrusive method can meet the need.

Sources: [3]

Retain the reasoning behind incident decisions

The Board's Decision 2019/10 interprets the notification period to the Board as without delay and no later than 72 hours after awareness. Communication to affected people follows its own requirements. Keep an assessment timeline, the relevant data categories and the decision owner; do not rely on a detector to make the notification decision.

Sources: [4]

Applying this with TRIAS

Evaluate TRIAS discovery and classification using the data types and business context in your approved scope. Test DLP policies with legitimate and prohibited sharing scenarios. Keep legal processing decisions and employee-monitoring governance separate from technical policy configuration.

• Data discovery and classification →
• Endpoint and channel controls →