Camera Recordings in Metropolitan Municipalities: Seven Practices Most at Odds with KVKK

⏱️ Reading time: 10 min · 📁 Category: KVKK, Camera Systems & Public Institutions

Camera Recordings in Metropolitan Municipalities: Seven Practices Most at Odds with KVKK

Camera recording systems in metropolitan municipalities (CCTV, MOBESE integrations, indoor cameras,
and park and public-square monitoring systems) are, under KVKK, among the highest-risk areas of data processing.
A review of Board decisions published up to 2025 shows that
a significant share of sanctions against municipalities are directly or indirectly related to camera recordings.

The main reason is that, although camera systems are often installed for “security”,
limits on retention, purpose, access and use are systematically breached.
Below, we examine
seven critical practices that are common in metropolitan municipalities and considered clearly contrary to KVKK.

Installing a camera system is not a violation in itself.
Violations arise from how the camera is used and for what purpose. 1. Indefinite and Excessive Retention Periods

One of the most common municipal violations concerns
camera recordings being retained for indefinite or unnecessarily long periods.
The Board explicitly rejects the “we will check if needed” approach.

• Retention “indefinitely” or “until needed”
• Setting the same long retention period for every area
• No automatic deletion mechanism

The Board’s approach is clear:
As a rule, camera recordings should be retained briefly; exceptions must be justified. 2. Use Beyond the Original Purpose: From Security to Discipline

Camera systems are often installed to protect life and property.
In practice, however, recordings are also used for purposes such as:

• Monitoring staff performance
• Conducting disciplinary investigations
• Controlling employee behaviour

These uses are observed in practice.
Such use clearly constitutes data processing beyond the original purpose.

3. Excessive and Unjustified Expansion of Camera Coverage

Camera placement plans in metropolitan municipalities often
cover areas so extensive that they breach the principle of proportionality.

• Rest areas
• Staff rooms
• Areas where citizens have a high expectation of privacy

Except in very exceptional cases, camera use in these areas
is considered contrary to KVKK.

4. Unauthorized and Uncontrolled Access

Who accesses recordings, under what authority and for what purpose
is unclear in most municipalities.

• Unauthorised staff being able to access footage
• Failure to keep access logs
• The “anyone can check if needed” approach

Under KVKK, access permissions
must be individual, limited and traceable. 5. Treating the Duty to Inform as a Mere Formality

Another common municipal mistake is
assuming a sign stating “This area is monitored by camera”
is sufficient in monitored areas.

In fact, the information provided must include:

• The data controller’s identity
• The processing purpose
• The retention period
• Data subjects’ rights

It must also be accessible and understandable.

6. Sharing Camera Recordings with Third Parties

Sharing camera recordings with:

• The press
• Social media accounts
• Unauthorised organisations or individuals

is one of the most serious types of violation.
Invoking “public interest” or “providing information”
does not automatically make these disclosures lawful.

7. Omitting Camera Systems from Inventories and Policies

In many municipalities, camera systems are operating,
but:

• They are absent from the data inventory
• Retention and access policies are not documented
• It is unclear how to handle them in data subject requests

Absence from the inventory
does not make them legally nonexistent; on the contrary, it is considered a direct violation. Why Are Camera-Related Violations So Common in Municipalities?

• Failure to question the “security” justification
• Failure to review technical systems legally
• Unclear powers and responsibilities
• Camera use becoming habitual

What Should Municipalities Do? (Summary)

• Clearly define the purpose of camera systems
• Set short, justified retention periods
• Make access permissions role-based and log access
• Ensure privacy notices reflect actual practice
• Include camera recordings in inventories and policies

Conclusion

Camera recordings in metropolitan municipalities
are the most sensitive area of KVKK compliance and generate the most violations.
The main causes of violations are
disproportionate use, purpose drift and a lack of control, rather than technology.

When managed incorrectly, camera systems cease to be a security tool
and expose municipalities to a high risk of administrative sanctions.

KVKK Analysis of Camera Systems