Two New Announcements from the Personal Data Protection Board on CCTV Camera Recording Systems

The Personal Data Protection Board (“Board”) has once again brought to the agenda the key points to be considered regarding the use of security cameras both in the common areas of apartment buildings/residential complexes and in workplaces, through two separate public announcements dated 8 June 2026. In fact, the warnings and recommendations emphasized through these announcements are not new:

In our article dated 2 April 2026, we discussed the Board’s principle decision dated 18 February 2026 and numbered 2026/348 regarding the posting of debt information belonging to apartment/residential complex residents in common areas such as building entrances, elevators and corridors.

We now see the same approach in relation to CCTV camera systems. Indeed, in its Public Announcement on the Points to Be Considered in the Use of Security Camera Systems in Apartment Buildings dated 8 June 2026, the Board states that cameras may be installed in apartment buildings and residential complexes, but such installation must be limited to legitimate purposes such as ensuring the security of common areas and protecting the interests of condominium owners. In this context, it was emphasized that camera placement in stairwells or at points that view the inside of an independent unit when the apartment door is opened, wide-angle recordings, audio recording or facial recognition features may create serious risks in terms of privacy and proportionality and may violate data security obligations. It was also underlined that, since elevators are areas that are difficult to avoid, the justification for placing cameras in such areas must be clearly stated; particular attention must be paid to the retention periods of the data processed through cameras installed in common areas; the obligation to inform data subjects must be fulfilled; and technical and administrative measures must be taken.

The picture is similar for workplaces. In our article dated 4 June 2026, we examined the Board’s approach to the processing of biometric data for attendance tracking purposes and emphasized that the main question for employers is not “Can I monitor?” but rather “Is this monitoring method truly necessary and proportionate?” The Board’s Public Announcement on the Points to Be Considered in the Use of Security Camera Systems in Workplaces dated 8 June 2026 follows the same line. Although employers may use cameras for purposes such as occupational health and safety, workplace security or the prevention of crimes, cameras should not be used to continuously monitor whether employees are working efficiently, to ensure general discipline or to conduct abstract performance supervision. Cameras should not be placed in private areas such as toilets, changing rooms, prayer rooms or rest areas.

As in the decision on biometric attendance tracking, and as we stated in our article dated 4 June 2026, employers should ask the following questions in relation to camera systems:

• Is this data processing activity truly necessary?
• Can the same purpose be achieved through a less intrusive method?
• Have the camera angle, retention period and access authorizations been limited?
• Has the obligation to inform been fulfilled?
• Has it been determined who may access the recordings, and have the necessary technical and administrative measures been taken?

In short, the Authority’s message is now quite clear: whether you are an apartment building management or an employer or any other data controller, and regardless of whether the personal data processing activity involves cameras, biometric systems, debt lists or any other monitoring tool, the processing must have a valid legal ground, the purpose must be specific, the method must be proportionate, access must be limited and the obligation to inform must be fully satisfied.