ÜNALLAR METAL İNŞAAT SANAYİ VE TİCARET ANONİM ŞİRKETİ
PERSONAL DATA STORAGE AND DESTRUCTION POLICY
ÜNALLAR METAL İNŞAAT SANAYİ VE TİCARET ANONİM ŞİRKETİ
PERSONAL DATA STORAGE AND DESTRUCTION POLICY
INFORMATION FORM
Document Name:
Ünallar Metal İnşaat Sanayi ve Ticaret Anonim Şirketi Personal Data Storage and Destruction Policy
Target Group:
All natural persons whose personal data are processed by Ünallar Metal İnşaat Sanayi ve Ticaret Anonim Şirketi
Prepared and Approved By:
Ünallar Metal İnşaat Sanayi ve Ticaret Anonim Şirketi Board of Directors
Version:
2.0
Effective Date:
20/02/2023
The Policy has been prepared in Turkish language and in case of translation into any other language, if there is a discrepancy between the translation and the Turkish text, the Turkish text should be taken into consideration.
CONTENTS
- INTRODUCTION
- PURPOSE AND SCOPE OF THE POLICY
- DEFINITIONS. 3
- TITLES, UNITS AND JOB DESCRIPTIONS OF PERSONS INVOLVED IN DATA STORAGE AND DESTRUCTION PROCESSES
- REGISTRATION ENVIRONMENTS REGULATED BY THE POLICY
- REASONS FOR STORING AND DESTROYING PERSONA DATA.
- DESTRUCTION METHODS OF PERSONAL DATA
- TECHNICAL AND ADMINISTRATIVE MEASURES TAKEN FOR SECURELY STORING PERSONAL DATA AND PREVENTING ILLEGAL PROCESSING AND ACCESS
- STORAGE AND DESTRUCTION PERIODS
- PERIODIC DESTRUCTION PERIODS
- ENFORCEMENT
ANNEX – 1 Storage and Destruction Periods Table
ANNEX – 2 Personal Data Categories
ANNEX -3 Personal Data Holders
ANNEX – 1 Storage and Destruction Periods Table
Process
| Data Owner | Storage Period |
Receiving, evaluating and finalizing job applications | Employee Candidate | The personal data of the candidates whose applications have been rejected and those who may be evaluated for future open positions will be stored for one year from the conclusion of the process. The others are destroyed during the first Periodic Destruction Period. It is determined which data of the candidates whose application has resulted in success should be transferred to the personnel file, and other personal data processed during the job application process are destroyed. |
Job Entry and Personnel Procedures | Employee | 10 years from the end of the employment period |
Payroll, scoring | Employee | 10 years from the end of the employment period |
Education activities | Employee Subcontractor Employee | 10 years from the end of the Legal Relationship or employment period |
Occupational Health and Safety Processes | Employee Subcontractor Employee | 15 years from the end of the Legal Relationship or employment period |
Sales Processes | Person Receiving the Product or Service | 10 years from the end of the agreement |
Information Security and Information Technologies Activities | Employee | Process Security Records are stored for 10 years from the end of employment. Other records are destroyed during the first Periodic Destruction Period after the termination of the legal relationship. |
Information Security and Information Technologies Activities | Visitor | Logging records are stored for 2 years. |
Vehicle Allocation Processes | Employee | GPS records are stored for 2 years. Vehicle Liability Reports are stored for 10 years from the conclusion of the legal relationship. Other records are destroyed during the first Periodic Destruction Period after the legal relationship ends. |
Finance and Accounting Transactions | Provider Employee/Executive | 10 years from the conclusion of the legal relationship |
Finance and Accounting Transactions | Employee | 10 years from the conclusion of the legal relationship |
Finance and Accounting Transactions | Person Receiving the Product or Service | 10 years from the conclusion of the legal relationship |
Activitiy Management | Participant | 1 year from the end of the activity |
Purchase Processes | Provider Employee/Executive | 10 years from the conclusion of the legal relationship |
Facility Security | Employee, Visitor | CCTV records are stored for 90 days. |
Institution Management Processes | Employee, Company Executive, Shareholder | 10 years from the conclusion of the legal relationship |
Lawsuit and Enforcement Processes | Legal Action Party, Person Receiving the Service | It is stored according to the quality of the case during the prescription. |
ANNEX – 2 Personal Data Categories
PERSONAL DATA CATEGORIES | EXPLANATION |
ID Information | The whole information about one’s name – surname, Turkish ID number, place of birth, sex, military status, workplace information, title, etc. with such documents as driver’s license, occupational identity, identity card, and passport and the information contained in these documents |
Contact Details | Information of telephone number, address, e-mail address, fax number, etc. |
Personnel Information | All kinds of processed personal data for obtaining information that will be the basis for the formation of the personal rights of natural persons who are in a working relationship with the Company |
Legal Action and Alignment Information | Information about the tracking of legal transactions, tracking and fulfilling our receivables and debts, fulfilling our legal obligations, personal data processed within the scope of dispute resolution and signatures that constitute a legal basis, etc. |
Location Information | Records of GPS system |
Physical Location Security Information | Personal data related to the records and documents taken at the entrance to the physical place, during the stay in the physical place; camera recordings, records taken at the entrance/exit point of the facility, etc. |
Process Security Information | Your processed personal data to ensure our technical, administrative, legal, and commercial security during the execution of our activities (for example, data such as device ID, IP information, authentication information, and internet access records) |
Financial Information | Personal data such as bank account number, IBAN number, debt/receivable information, wage information, as well as personal data processed related to information, documents, and records showing all kinds of financial results created according to the type of legal relationship the company has established with the personal data owner |
Occupational Experience Information | Personal data about received training of employees and those who applied for a job, professional competency information, title, information regarding work experience, etc |
Visual Audial Data | Photograph and camera records |
Health Information – Sensitive Personal Data | In order to perform our legal responsibilities within the scope of conducting the recruitment, personnel, and work health and work security processes health information such as processed disability information, examination results, blood type information, accident status, incapacity, etc. based on the explicit consent condition |
Data About Conviction and Security Measures – Sensitive Personal Data | Within the scope of conducting recruitment process, sensitive personal data such as criminal record certificate, criminal record, etc. for the purpose of creating personal file |
Family Members and Close Relatives Information | Within the frame of actions conducted by the Company or for the purpose of protecting the legal interest of the Company and employees; received and processed information about these people’s family members and close relatives (partner/children information, a close relative’s phone number, contact person in case of emergency, etc.) |
Employee Candidate Information | Processed personal data about individuals, who applied for a job or internship to the Company, considered as employee candidate in line with our human resources needs by customs of trade and good faith |
Request/Complaint Information | Information or petitions, etc. regarding requests and complaints communicated about various subjects by those who receive products or service from the Company, employees, and applicant |
Performance and Career Development Information | During the employment of employees, data such as assignation/promotion, performance assessment information in order for tracking their performance and career development |
Process Information | Data such as cookie records, travel information, and shift information within the scope of work activities of our Company |
Client Process Information | Data such as every kind of instruction received from its clients and order status of clients within the scope of our Company |
ANNEX -3 Personal Data Holders
CATEGORIES OF PERSONAL DATA HOLDERS | EXPLANATION |
Employee | Natural persons who have a work relationship with our Company within the coverage of a contract of employment |
Employee Candidate | Natural persons who applied for a job through any method or disclosed their Curriculum Vitae and relevant information to review by our Company (including intern candidates) |
Company Official | A board of directors member of our Company and other authorized natural persons |
Shareholder | Natural person partners of the company |
Employees, Officials of the Institutions with which We Cooperate | Natural persons who work for institutions with which our Company has any business relationship (including but not limited to business partners, suppliers, and sub-employer), including shareholders and officials of these institutions |
Participant | Natural persons who attend events organized by the company |
Person Receiving the Product or Service | Natural persons who procure products or services from our Company regardless of whether they have a contractual relationship with our Company or not |
Visitor | Natural persons who enter the physical premises of our Company or visit our websites |
Party to Legal Proceedings | Natural persons (ex-employee, etc.) who are parties to the legal proceedings carried out by the company |
Data Owner Application Form
ÜNALLAR METAL
DATA OWNER IS WITHIN THE SCOPE OF APPLICATION PROCESS
CLARIFICATION TEXT ON THE PERSONAL DATA PROTECTION AUTHORITY
Pursuant to the Personal Data Protection Law No. 6698 (the “Law”), your personal data may be processed by Ünallar Metal Construction Industry and Trade Joint Stock Company (“Ünallar Metal” or the “Company”) as the data controller within the scope described below.
Detailed information about the purposes of processing your personal data by the Company; https://unallarmetal.com/kisisel-verilerin-korunmasi/kvkk-politikasi/ located at the address Ünallar Metal Construction Industry and Trade Joint Stock Company, you can access the Personal Data Protection and Processing Policy.
Purpose of Personal Data Processing
Identity, Communication, Request and Complaint, Dispute Subject Information obtained within the scope of the Data Subject Application Process; Evaluation and conclusion of your applications submitted to our Institution within the scope of exercising your rights specified in Article 11 of the Law, storage during the general statute of limitations for the purpose of providing evidence in possible legal disputes, tracking and conducting legal affairs, fulfilling official institution requests and providing information to authorized organizations based on legislation are processed.
To whom and with what Purpose the Processed Personal Data can be Transferred
Your processed personal data within the scope of the purposes listed above; provided that it does not harm your fundamental rights and freedoms, if it is mandatory to ensure the legitimate interests of our company, to the people we provide legal advice to, to our suppliers to whom we transfer data depending on the conditions for the establishment, use, and protection of a right as clearly stipulated in the Laws, the establishment of a right, based on the condition that data processing is mandatory for use and protection and fulfillment of the Company’s legal obligation, it may be transferred to legally authorized public institutions and legally authorized private persons, including the Personal Data Protection Authority, in accordance with the personal data processing conditions specified in the Article 8 of the Law.
Method and Legal Reason of Personal Data Collection
Your personal data is collected by means of the application form, petition, or e-mail on the Ünallar Metal website, which you transmit electronically and physically depending on the application method you have made to our Company.
Your personal data is collected and processed in accordance with the personal data processing conditions specified in Article 5 of the Law, based on the legal reasons that data processing is mandatory to ensure the legitimate interests of our Company, provided that it does not harm your fundamental rights and freedoms, it is clearly stipulated in the Laws, and the fulfillment of the legal obligation of our Company and the necessity of data processing for the establishment, use, and protection of a right.
Enumerated Rights of the Personal Data Holder In the Article 11 of the Law
We hereby declare that you as the personal data holder, have the following rights in accordance with Article 11 of the Law:
- Learn if the personal data is processed or not;
- Demand information if the personal data is processed with regards to this;
- Learn the purpose of personal data processing and whether they are used relevant to their purpose;
- Know the third parties to whom the personal data information is transferred both abroad and at home;
- In the event that personal data is processed incompletely or incorrectly, demanding a correction and requesting that the procedure carried out within this scope is communicated to the third persons to whom the personal data is transferred;
- Requesting the deletion or destruction of personal data in the event that the reasons requiring its processing cease to exist despite the fact that it has been processed in accordancewith the provisions of Law No. 6698 and other relevant laws, and requesting the notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,
- Objecting to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems,
- To request the compensation of the damage in case of damage due to unlawful processing of personal data.
You can submit your applications regarding your rights listed above to our Company by filling out the Data Owner Application Form, which you can access at https://unallarmetal.com/wp- content/uploads/2023/01/KVK-BasvuruFormu.pdf. Depending on the nature of your request, your applications will be concluded free of charge as soon as possible and within thirty days at the latest; however, if the transaction requires an additional cost, you may be charged a fee according to the tariff determined by the Personal Data Protection Board.