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Employee Clarification Text on the Protection and Processing of Personal Data


FATIH SULTAN MEHMET MAH. BALKAN CAD.  As ODC İş Çözümleri Danışmanlık Ticaret A.Ş or “SmartMessage“, operating at NO: 62/A ÜMRANİYE/İSTANBUL, we show maximum sensitivity to the security of your personal data. With this awareness, we attach great importance to the processing and preservation of personal data belonging to real persons who want to work within the Company and apply for a job in accordance with the Law on the Protection of Personal Data No. 6698 (“Law”), the secondary regulations (regulation, communiqué, circular) put into effect and to be put into effect in accordance with the Law, and the decisions taken or to be taken by the Personal Data Protection Board, which are binding. With the full understanding of this responsibility, we process your personal data as defined in the Law as “Data Controller” as explained below and within the limits ordered by the legislation. 

1. Information Regarding the Data Controller: 

In accordance with the law, it is the Data Controller registered in the Istanbul Trade Registry Directorate with the registration number 562273-0  and 0634042637100018 with MERSIS number. 

2. Purposes of Processing Personal Data: 

 Personal data belonging to real persons working as insured within SmartMessage by the Company; 

  • Fulfillment of the obligations arising from the Law on the Protection of Personal Data No. 6698, 
  • Fulfillment of the obligations arising from the Labor Law No. 4857, 
  • Fulfillment of the obligations arising from the Social Insurance and General Health Insurance Law No. 5510 and the secondary regulations related to the Law,  
  • Fulfillment of the obligations arising from the Occupational Health and Safety Law No. 6331 and the secondary regulations related to the Law,  
  • Execution of emergency management processes, 
  • Execution of information security processes, 
  • Execution of employee satisfaction and loyalty processes, 
  • Fulfillment of obligations arising from employment contract and legislation, 
  • Execution of fringe benefits and benefits processes for employees, 
  • Execution of audit / ethics activities, 
  • Carrying out vocational training activities, 
  • Ensuring the security of physical space, Follow-up and execution of legal affairs, 
  • Planning of human resources processes, 
  • Execution and supervision of business activities, 
  • Carrying out occupational health / safety activities, 
  • Receiving and evaluating suggestions for the improvement of business processes, 
  • Carrying out activities to ensure business continuity, 
  • Development of marketing strategies, 
  • Execution of the wage policy, 
  • Carrying out talent / career development activities, 
  • Providing information to authorized persons, institutions and organizations, 
  • Tracking entry and exit to the workplace, 

It is processed in accordance with the law, the rules of honesty within the limits specified in the Law, and always connected with these purposes, in a limited and measured manner. 

3. Transfer of Personal Data: 

Your personal data, in accordance with the conditions specified in Articles 8 and 9 of the Law, within the purposes listed above, is transferred to the employees and managers of the Company’s Accounting Department, Company unit officials, İŞKUR, SSI, judicial and administrative judicial authorities, police units, etc. Legally authorized public institutions and organizations, the private employment agency with which the Company has an agreement, the workplace physician contracted by the company, the Ministry-approved training institutions for the purpose of obtaining vocational training and certificates directly related to the performance of the employment contract, the relevant institutions for the purpose of issuing participant certificates in organizations carried out for internal and external training, etc., the supplier company contracted by the Company for catalog shooting and business card printing,  to the institution from which the incentive is received, to the relevant financial institution for the purpose of fulfilling obligations such as PPS, to the company with which the Company has an agreement due to the allocation of vehicles to the employees, to the bank where the Company works in order to make payments regarding salaries and other fringe benefits, to the suppliers from whom the Company receives outsourced services in direct connection with the employment contract, to the companies with which we have a business relationship for the purpose of carrying out the business, to the suppliers for the realization of business trips,  to the institutions and organizations that work for the purpose of carrying out human resources management and informatics systems, with Technoparks for the purpose of notifying R&D projects, with domestic and foreign companies from which services are received for the purpose of conducting various tests, trainings and exams, to servers abroad for the use of cloud systems, to the lawyer(s) to whom the Company has given power of attorney when necessary, to the foreign-based companies with which the Company has a business relationship.  

4. Methods of Collecting Personal Data and Legal Reasons 

Your personal data; It is collected verbally, in writing or electronically by automatic and non-automatic methods by real or legal persons who process data authorized by the Human Resources Department, the General Directorate and the Company, through means such as e-mail, telephone, website, various contracts, forms and minutes kept in paper environment.  

In this context, your private and general personal data of the following nature are processed and collected in the above-mentioned ways: 

Identity Such as name, surname, parents’ name, date of birth, place of birth, marital status, identity card serial sequence number, TR identity number, passport. 
Communication Such as address number, e-mail address, contact address, registered e-mail address (KEP), telephone number. 
Aslam Such as payroll information, disciplinary investigation, employment-exit document records, resume information, performance evaluation reports. 
Legal Action Information in correspondence with judicial authorities, such as information in the case file. 
Financial Data Financial and salary details, payrolls, premium entitlements, premium amounts, file and debt information related to enforcement proceedings, bank passbook, minimum living allowance information, private health insurance amount. 
Transaction Security Such as IP address information, website login and exit information, password and password information, log records. 
Professional Experience Details given about his professional experience. 
Audiovisual Recordings Photo, camera recordings. 
Criminal Record Information Criminal record. 
Health Information Information on disability status, blood group information, personal health information, device and prosthesis information used, private health insurance policy, health reports, on-the-job health report, chest X-ray, employment and periodic examination forms signed by the workplace physician, pregnancy status, pregnancy report, health and maternity leave information. 
Other Notices to be made due to acts contrary to the rules of operation of the workplace, contact person information in order to be contacted in case of emergency. 

Your personal data in question is processed and collected by the Company for the following legal reasons: 

Identity Article 5/2 (c): Establishment and performance of employment contract 
Communication Article 5/2 (c): Establishment and performance of employment contract 
Aslam Article 5/2 (c): Establishment and performance of employment contract, Article 5/2 (a): Expressly stipulated in the laws 
Legal Action Article 5/2 (ç): Fulfillment of Legal Obligation 
Financial Data Article 5/2 (c): Establishment and performance of the employment contract, Article 5/2 (ç): Fulfillment of Legal Obligation 
Transaction Security Article 5/2 (c): Establishment and performance of the employment contract, Article 5/2 (f): Legitimate interest 
Professional Experience Article 5/2 (c): Establishment and performance of the employment contract, 
Audiovisual Recordings Article 5/2 (c): Establishment and performance of the employment contract, Article 5/2 (f): Legitimate interest 
Criminal Record Information Article 6/2: Explicit consent 
Health Information 

Article 5/2 (c): Establishment and performance of the employment contract Article 5/2 (ç): Fulfillment of Legal Obligation, Article 6/3: Processing by persons with a confidentiality obligation,  

Article 6/2: Explicit consent 

Other Article 5/2 (c): Establishment and performance of the employment contract, 

 5. Rights of Data Owners under the Law 

By applying to SmartMessage at any time; 

  • To learn whether your personal data is processed or not,  
  • If your personal data has been processed, requesting information about it, 
  • To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,  
  • To know the third parties to whom your personal data is transferred at home or abroad,  
  • Requesting correction of your personal data in case of incomplete or incorrect processing,  
  • Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the Law,  
  • Requesting notification of the transactions made pursuant to subparagraphs (d) and (e) of Article 11 of the Law to third parties to whom your personal data has been transferred,  
  • Objecting to the occurrence of a result against yourself by analyzing your processed data exclusively through automated systems, 
  • Requesting the compensation of the damage in case you suffer damage due to the unlawful processing of your personal data, 

You can request to exercise your rights. You can submit your requests regarding your rights and the implementation of the Law from   the workplace or by filling out the application form you can obtain from the workplace or to the address “  Fatih Sultan Mehmet Mah, Balkan Cd. No: 62/A, 34771 Ümraniye/Istanbul” through a notary public, by registered mail with return receipt requested, or with your personal application, or after signing the application form you filled out electronically with your mobile signature, secure electronic signature, you can send your KEP address or your KEP address or in the Company’s data recording system You can forward it to using your registered e-mail address. If the Company is to respond  in writing to requests within this scope, without charging up to ten pages; It will respond by charging a transaction fee of 1 Turkish Lira for each page over ten pages. If the response to the application is given in a recording medium such as CD or flash memory, the fee that may be requested by the Company will not exceed the cost of the recording medium. 

The employee will fulfill the requests arising from the Law through the “Relevant Person Application Form“. SmartMessage will conclude application requests free of charge in accordance with Article 13 of the Law, depending on the nature of the request and within 30 (thirty) days at the latest. If the request is rejected, the reason(s) for the rejection shall be notified in writing or electronically with the justifications. 

The employee undertakes that the personal data subject to this Clarification Text is complete, accurate and up-to-date. In case of any changes regarding their personal data, they will be able to request that their personal data be updated by informing SmartMessage. If the Employee does not provide accurate and up-to-date information, SmartMessage will have no responsibility. 

This Clarification Text will be valid as of the date it is published by SmartMessage. SmartMessage may amend this Privacy Notice at any time, if necessary. The changes to be made become effective upon the publication of the Clarification Text on the corporate web address of the