KVKK Period in Apartment and Site Managements: Hanging the Debtor List Is Forbidden!

1. It Will Be Considered “Personal Data” Even If It Doesn't Write a Name
Many administrations thought that they could escape legal obligation by simply sharing apartment numbers instead of first and last names on debt lists. However, the Board made a clear point on this issue: the criterion of “determinability”. Even if there is no name on the list, the debt information paired with the apartment number falls under the scope of “personal data” because it makes that person identifiable. Therefore, it is now against the law to hang debt lists in public areas where everyone can see, such as elevators, building entrances, block doors and corridors
.2. End Sharing in WhatsApp Groups
WhatsApp groups that administrations use to communicate quickly or create social pressure have also been banned. The method of “sharing a list of debtors through the group”, which damages relations between neighbors and violates personal data, may now face heavy sanctions.
3. How Should Debt Statements Be Filed?
With the new regulation, it has become imperative for administrations to strike a balance between transparency and confidentiality in their debt tracking processes. According to the decision:
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All lists of debtors hanging on the boards should be removed immediately.
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Debt notifications and payment reminders should only be made through channels specific to the person concerned (SMS, email, closed envelope or mobile application notifications).
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