Personal data refers to any information relating to an identified or identifiable natural person. In order to be able to talk about personal data, the data must be related to a natural person and this person must be specific or identifiable.
1. Relating to a real person: Personal data relates to a real person, and data related to legal entities are outside the definition of personal data. Therefore, information regarding a legal entity such as the trade name or address of a company (except when they can be associated with a natural person) will not be considered personal data.
2. Render the person specific or identifiable: While personal data can show the identity of the person concerned, it does not show the identity of that person directly, but also includes all the information that enables the person to be identified as a result of associating with any record.
3. All kinds of information: This expression is extremely broad and regarding information for a natural person such as name, surname, date of birth, and place of birth is not enough information that reveals the identity of the individual. In this context, all data such as phone number, motor vehicle license plate, social security number, passport number, resume, pictures, video and audio recordings, fingerprints, e-mail address, hobbies, preferences, people interacted with, group memberships, family information, health information which make the person identifiable or indirectly identifiable are considered personal data.
Since there is no method limiting the framework of information to be considered as personal data in the law, it is possible to expand its scope. The important thing is that the data is associated with the person or can identify him.
For example, if pseudonyms, alone or combined with other sources, are capable of identifying the person, such data is also considered personal data. In addition, frequently used reports such as customer complaint reports, employee performance evaluation reports, interview evaluation reports related to an identified or identifiable natural person and furthermore, records such as audio or video recordings, pictures, user transaction records, documents such as resumes, payrolls, invoices, bank receipts, credit card statements, photocopies of identity cards, and the data included in letters/records such as invitation letters can also be considered as personal data.
However, whether these are personal data or not should be evaluated by taking into account the ability to "identify the person" according to the characteristics of each concrete case.
