ARTICLE
29 October 2025

Compliance Requirements Under Turkish Data Protection Law Processing Biometric Data

HH
Hamzaoglu Hamzaoglu Kinikoglu Attorney Partnership

Contributor

HHK is an Istanbul-based, full-service law firm delivering innovative, business-focused legal solutions across technology, privacy, corporate, and regulatory matters, helping clients navigate complex legal landscapes with strategic, multidisciplinary expertise and a client-first mindset.
Biometric data, defined as unique identifiers like fingerprints, facial recognition, and iris scans, are categorized as special categories of personal data under the Turkish Data Protection Law ("TDPL") and are subject to additional safeguards.
Turkey Privacy

I. Introduction

Biometric data, defined as unique identifiers like fingerprints, facial recognition, and iris scans, are categorized as special categories of personal data under the Turkish Data Protection Law ("TDPL") and are subject to additional safeguards. This memo aims to provide an overview of the compliance requirements for biometric data processing under TDPL, highlighting the necessary compliance measures and obligations for organizations operating in Turkey.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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