PERSONAL DATA STORAGE, DESTRUCTION, AND ANONYMIZATION POLICY
1 – PURPOSE AND SCOPE
The Personal Data Storage and Destruction Policy (“Policy”) has been prepared to establish the procedures and principles related to storage and destruction activities carried out by Pekerler İnşaat Enerji Taş. Tur. San Tic. Ltd. Şti. (hereinafter referred to as the "Company").
As a Company, our primary principle is to process personal data belonging to our customers, patients, employees, job applicants, service providers, visitors, and other third parties in compliance with the Turkish Constitution, international agreements, Law No. 6698 on the Protection of Personal Data (“Law”), and other relevant legislation. Ensuring that relevant individuals do not lose their rights and can exercise them effectively is a priority.
This Personal Data Storage and Destruction Policy has been prepared in compliance with the Personal Data Protection Law No. 6698, the Regulation on the Deletion, Destruction, or Anonymization of Personal Data published in the Official Gazette dated October 28, 2017, and other relevant legislation.
2 – DEFINITIONS
| Data Recipient Group | The category of natural or legal persons to whom personal data is transferred by the data controller. |
| Explicit Consent | Consent based on information and freely given for a specific matter. |
| Anonymization | Making personal data impossible to associate with an identified or identifiable individual, even when matched with other data. |
| Employee | Personnel of Pekerler İnşaat Enerji Taş. Tur. San Tic. Ltd. Şti. |
| Electronic Environment | Environments where personal data can be created, read, modified, and written via electronic devices. |
| Non-Electronic Environment | All written, printed, and visual media other than electronic environments. |
| Service Provider | Natural or legal person providing services under a specific contract with the Personal Data Protection Institution. |
| Data Subject | The natural person whose personal data is processed. |
3 – DATA STORAGE MEDIA
The following table class="table table-bordered" indicates the types of media where personal data stored by Pekerler İnşaat Enerji Taş. Tur. San Tic. Ltd. Şti. is recorded. Personal data retained by our Company is stored in the most appropriate media according to its nature and legal status.
| Data Storage Media | Description |
| Electronic Media | · Servers (Backup, Email, Web, File Sharing, etc.) · Information Security Devices (Firewall, Log Files, Antivirus, etc.) · Company Computers (Desktop, etc.) · Company-Owned Mobile Devices (Phone, etc.) · Removable Memory (USB, etc.) |
| Non-Electronic Media | · Paper · Printed, visual, and written environments |
4 – RESPONSIBILITIES AND DUTY DISTRIBUTION
In accordance with Article 6(f) of the Regulation, it is required to specify the titles, duties, and units of the individuals involved in data storage and destruction processes. Therefore, the roles, duties, and units of individuals within the Company responsible for preventing illegal processing and access to personal data, as well as ensuring the lawful retention of personal data, have been specified.
| Title | Job Description |
| Personal Data Manager | Responsible for managing projects conducted to ensure compliance with the Law, including planning, analyzing, researching, identifying risks, and evaluating requests from related parties. |
5 – TECHNICAL AND ADMINISTRATIVE MEASURES
Pekerler İnşaat Enerji Taş. Tur. San Tic. Ltd. Şti. takes all necessary technical and administrative measures to securely store personal data and prevent illegal processing or access, appropriate to the nature of the personal data and the media in which it is stored.
5.1 Technical and Administrative Measures
Our Company applies the following technical measures:
- Network and application security is ensured.
- Closed network systems are used for personal data transfer.
6 – PERSONAL DATA DESTRUCTION TECHNIQUES
Pekerler İnşaat Enerji Taş. Tur. San Tic. Ltd. Şti. uses various methods for securely deleting, destroying, or anonymizing personal data.
6.1 Data Deletion Techniques
| Deletion Techniques for Physical Media | |
| Redaction | Personal data in physical documents is redacted using methods that make it irretrievable and unreadable. |
8 – STORAGE AND DESTRUCTION PERIODS
| Process | Storage Period | Destruction Period |
| Data kept under Labor Law (e.g., performance records) | 10 years following the termination of employment | Within 180 days after the storage period ends |
10 – PUBLICATION, STORAGE, AND UPDATING OF POLICY
This Policy is published in both printed and electronic formats and made publicly available on the website of Pekerler İnşaat Enerji Taş. Tur. San Tic. Ltd. Şti..
This document is written according to Turkish Law, and the original Turkish text is authoritative in cases of ambiguity or discrepancies arising from translation.