The Turkish DPA’s 2026/921 Principle Decision on Biometric Time Tracking
Important note: This article explains the Turkish DPA’s April 29, 2026 notice concerning the 2026/921 principle decision and public consultation. The current official text and a case-specific assessment remain decisive.
What the notice reports
The official notice communicates a consultation process concerning biometric data processing for time tracking. It should not be treated alone as a blanket permission or prohibition for every workplace.
Three interpretation limits
- Preserve the official scope, date, and legal character.
- Assess purpose, affected workers, alternatives, data flows, and safeguards in context.
- Update the article when later official statements are published.
Employer checklist
- Is biometrics genuinely necessary?
- Could QR, a card, or an authorized app achieve the same purpose with less intrusion?
- Are data, retention, and access documented?
- Were employees clearly informed?
- Were supplier, processor, security, and breach controls assessed?
- Is there a correction and challenge process?
Conclusion
The 2026/921 notice makes biometric time tracking a current governance issue, but it is not an automatic permission document. Employers should document necessity, proportionality, alternatives, and safeguards.
Sources
This article is for general information and is not legal advice.