Can your employer track your arrivals and departures with your fingerprint?

22 October 2026Prof. Dr. Murat Volkan DülgerVideo · short · 1:11

The video is in Turkish.

About the video

An employer may track arrivals and departures to organise work and document working hours, but a legitimate aim does not justify every method. Biometric data such as fingerprints, facial recognition or iris scans are special categories of personal data, and processing them is prohibited as a rule.

According to the Personal Data Protection Board’s principle decision of 29 April 2026, there is no express statutory provision for tracking working hours with a biometric system; because of the imbalance of power between employee and employer, the employee’s explicit consent alone is not sufficient; and where less intrusive methods such as a card, a PIN or a signature sheet are available, using a biometric system breaches the principle of proportionality even if explicit consent has been obtained.

Legal basis: Law No. 6698 on the Protection of Personal Data (KVKK), Arts. 4, 6 and 10; Personal Data Protection Board Principle Decision No. 2026/921 of 29 April 2026.