NEWSLETTER-2017

326 NEWSLETTER 2017 Removal of Personal Data Pursuant to the Regulation, the removal of personal data is the process of rendering personal data inaccessible, irretrievable and ir- revocable by anyone. The data controller is obliged to take all neces- sary technical and administrative measures regarding the removal of personal data. For the removal of personal data, all copies of the data should be identified and then removed individually depending on the systems where data is located (such as local systems, environmental systems, paper and microfiche, and cloud environment). In order to remove data on local systems, the methods of de-magnetizing, physically removing (such as dissolving, burning or dusting optical and magnetic media) and overwriting data can be used. In environmental systems, methods of removal that can be used in connection with various media types are discussed in detail in the Guideline. Since the personal data in paper and microfiche are permanently and physically written on the media, the master media must be re- moved. During this process, it is necessary to divide the media into small pieces with paper removal or shredding machines so that it cannot be combined back and forth and, if possible, horizontally and vertically, in incomprehensible sizes. Personal data transferred from paper format to electronic media by scanning should be removed by using one or more methods, such as de-magnetizing, physically re- moving, and overwriting according to the electronic media in which they are stored. During storage and use of personal data in the cloud environment, cryptographic methods and individual encryption keys must be used wherever possible, especially for each served cloud solution. When cloud computing service relationship ends, all copies of the encryp- tion keys required to make personal data available must be removed. Additionally, the methods of removing personal data contained in malfunctioning devices, or for the devices taken to maintenance, are also listed in the Guideline.