NEWSLETTER-2017

334 NEWSLETTER 2017 Registration with the Registry of Data Supervisor The LPPD regulates a Registry for Data Supervisor; however, this registry has not yet been created. Elimination of The Employer’s Remaining Data As mentioned, above, pursuant to the LPPD, employers cannot archive information unless it is legally necessary. Therefore, the CV’s of candidates who have not been employed, should be deleted or ano- nymized, and should not forward the same to other employers without the written consent of the candidates. The employers shall delete or anonymize the data of the persons who have resigned from employ- ment, as the case may be, at the end of the statute of time limitation considering a possible litigation, and/or at the end of the legal retention period (for example, the documents regarding health controls should be kept for 15 years). The information regarding employees’ habits, emotional, social, economic structures, and characteristics must be destroyed. The employees shall be entitled to demand the erasure of this data, as well. This right is defined as “the right to be forgotten” in doctrine 6 . Policy Formulation Temporary Article 2 of the LPPD grants time until 26.03.2018 in order to fulfill the abovementioned obligations. Within this period, employers should make comprehensive archive surveillance, catego- rize their data as general or special, determine how to protect them, and who may have access to them, and keep them confidential with high-level precautions. They should state the unnecessary information in line with the abovementioned principles and erase them, and/or ob- tain written consent that the LPPD foresees, from the owners. Finally, in order to ensure that the system works smoothly, they should audit their workplace regularly. In addition, it can be beneficial to create a drill plan against a risk of a cyber-attack. 6 For detailed information please see: http://www.erdem-erdem.av.tr/publications/ newsletter/the-eu-general-data-protection-regulation-and-its-territorial-scope/ (Accessed on 01.08.2017).