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Employee privacy notice template

Privacy notice template under KVKK that you can give to your employees before installing the agent.

This text has been machine-translated from the Turkish original; the Turkish text is binding.

This is a template. norvo IT customers may fill in and adapt this text with their own information before deploying the agent, to give to their employees. Fill in the fields in square brackets yourself. We recommend having your own legal advisor review the text before using it; workplace-specific conditions (collective agreement, internal regulations, BYOD) may require additional provisions.

Employee Privacy Notice — Computer Usage Data

[COMPANY NAME] ("Company"), in accordance with Article 10 of Turkish Personal Data Protection Law No. 6698 ("KVKK"), would like to inform you about the time-tracking software used on work computers.

1. Data controller

[COMPANY NAME], [ADDRESS], [E-MAIL / KEP]

2. What data is collected

The software installed on Company computers collects the following data only during working days and hours ([WORKING HOURS]):

  • Name and usage time of the application in the foreground (the one you are currently using),
  • Periods during which the computer is active or idle (no keyboard/mouse movement),
  • [IF WINDOW TITLE STORAGE IS ON:] Title of the active window (e.g. name of the open document or web page),
  • Computer name and the username you are logged in with.
  • [IF STAFF DIRECTORY IS CONNECTED:] From the Company user directory ([Microsoft 365 / Google Workspace / Active Directory]): your first and last name, username, department and account status (active/inactive), to keep the staff list up to date; your e-mail address and other directory information are not retrieved.
  • [IF HARDWARE INFORMATION IS ON:] Hardware and system information of the computer: model, serial number, processor, memory, disks, battery status, operating system version and last update, security status (disk encryption, firewall, antivirus), and, during working hours, processor, memory and disk utilisation rates, network and disk read/write speeds and the names of the five programs using the most resources at that moment, measured every [MEASUREMENT INTERVAL: 1–10 minutes][; IF OFF-HOURS MEASUREMENT IS ON: these usage measurements are also taken outside working hours][; IF NETWORK INFORMATION IS ON: local IP and MAC address] (for computer maintenance, capacity planning and security; files or content are not read).
  • [IF INSTALLED PROGRAMME LIST IS ON:] List of programmes installed on the computer: programme name, version, publisher and installation date; once a day and only when the list changes (for tracking software licences and detecting unauthorised software; the contents or usage content of programmes are not read).
  • [IF IT ASSET MODULE IS USED:] Company equipment assigned to you: type, brand/model, serial number, assignment and return dates, and handover/return condition notes (for equipment and assignment tracking).
  • Agent operating status: time of last connection to the server, times of computer shutdown, restart and sleep, session logoff, and agent stopping or being out of date (to monitor proper operation of the agent and any interference with it; contains no application or content information).

Not collected: screenshots, screen recordings, keystrokes, texts you type, e-mail or message contents, file contents, camera, microphone and location data are not collected. No activity data (application, duration, window title) is collected outside working hours; only the operating status above and, if enabled, a daily hardware inventory and installed programme list are recorded.

3. Purpose

  • Planning of work processes and workload distribution,
  • General evaluation of working hours and productivity,
  • Ensuring that Company information systems are used for their intended purpose and information security is maintained.
  • [IF IT ASSET MODULE IS USED:] Tracking of Company equipment, assignments and software licences; licence compliance and computer renewal planning. For this purpose, whether a licensed programme was opened on your computer within the last 90 days may be determined from the application usage data above (so that the licence can be transferred to another person who needs it; not used for personal evaluation).

The data is not used alone as a basis for any disciplinary action or automated decision; [IF NEEDED: any evaluation is carried out by your manager, in discussion with you].

KVKK Art. 5/2(f): the Company's legitimate interest (work organisation and information security), provided that your fundamental rights and freedoms are not harmed; and Art. 5/2(c): necessity for the performance of the employment contract. The data collected is limited and proportionate to these purposes.

5. Who can see it

Within the Company, your data can only be viewed by [AUTHORISED PERSONS: e.g. human resources and your department manager]. Every access to your personal work details is recorded together with information on who accessed it and when.

6. Transfer and overseas processing

Data is processed by our service provider N2mobil Takip Sistemleri A.Ş. (norvo IT) on behalf of and under the instructions of the Company (data processor). Data is stored in N2mobil data centres in Turkey. Some service providers used for network security and e-mail delivery are located abroad, so data sent to these providers is transferred abroad. This transfer is carried out under KVKK Art. 9 on the basis of [TRANSFER BASIS: e.g. standard contract announced by the Board].

7. Retention period

Data is retained for [RETENTION PERIOD: e.g. 90] days and is automatically deleted at the end of this period. Usage measurements are retained for at most 30 days. Records of programmes removed from the computer are deleted at the end of the same retention period. [IF IT ASSET MODULE IS USED:] Assignment records are retained until the equipment record is deleted or the Company's use of the service ends.

8. Your rights

Under KVKK Art. 11 you have the right to learn whether your data is processed, to request information, to learn whether it is used in line with its purpose, to know the third parties to whom it is transferred, to request correction and deletion, to object to a result that is against you arising from analysis exclusively by automated systems, and to request compensation for damage. You may send your requests to [APPLICATION ADDRESS / E-MAIL]; they are answered free of charge within 30 days at the latest.

I have read this notice and have been informed.

Full name: ______________________ Date: ____________ Signature: ____________