Apartment CCTV: Sample Assembly Resolution and Privacy Notice

What Decision Is Needed to Install CCTV?

Installing security cameras in common areas is an improvement that increases the benefit derived from those areas. Under Article 42 of the Condominium Law such works are carried out on a resolution passed by a majority of owners both by number and by land share.

Cameras installed without a resolution can be the subject of an action for prevention of interference and restoration. A manager cannot install cameras alone.

Where May Cameras Be Placed?

• Acceptable: the main entrance, car park, garden, a general view of shared corridors
• Not acceptable: angles showing unit doors directly, lift interiors are contentious, neighbours' balconies or windows
• Strictly prohibited: private areas such as toilets, showers and changing rooms

Cameras should be positioned only so far as the security purpose requires, avoiding any angle that intrudes on private life.

Data Protection Duties

CCTV recording is processing of personal data. The data controller is the general assembly, with the management carrying out the operations. The core duties are:

• Displaying a visible notice in areas covered by cameras
• Preparing a privacy notice and communicating it to residents
• Retaining recordings only for security purposes and for a limited period
• Restricting and logging access to the recordings
• Not sharing recordings with third parties or posting them in groups

Copyable Assembly Resolution Sample

……………………… APARTMENT / COMPLEX

GENERAL ASSEMBLY RESOLUTION

Resolution No: ……    Date: …/…/20…

Agenda item: Installation of a CCTV system in common areas.

Units represented at the meeting: …… / ……   Land share represented: …… / ……

RESOLVED: For the security of the building, a total of …… security cameras shall be installed at the main entrance, the car park entrance and the garden, and the system shall be installed by ……………… at a cost of ………… TRY.

The installation cost and monthly running costs shall be shared among the owners in proportion to their land shares pursuant to clause …… of the management plan.

Cameras shall be positioned to cover common areas only; angles showing unit doors or neighbours' windows and balconies shall not be used.

Recordings shall be retained for …… days and automatically deleted thereafter. Access shall rest solely with the manager and recordings shall be provided to judicial authorities on request.

A notice shall be displayed in areas covered by cameras and the privacy notice shall be communicated to residents.

The resolution was adopted by ……… votes in favour and ……… against, by majority / unanimity.

Chair ……………… Signature    Secretary ……………… Signature

Copyable Privacy Notice Sample

……………………… APARTMENT / COMPLEX

CCTV PRIVACY NOTICE

Data Controller: ……………………… Apartment/Complex General Assembly, represented by Manager ……………… (Full Name)

1. Data processed: Images are recorded by security cameras in common areas. No audio is recorded.

2. Purpose: To ensure the security of the building and its residents and to prevent and identify incidents such as theft and damage in common areas.

3. Legal basis: Processing is carried out on the basis of the data controller's legitimate interest, provided it does not harm the fundamental rights and freedoms of the individual.

4. Areas covered: Main entrance, car park, garden. The interiors of units, unit doors and private areas are not recorded.

5. Retention: Recordings are kept for …… days and deleted automatically thereafter.

6. Transfers: Recordings are not shared with third parties. They are transferred only to competent judicial and administrative authorities on request.

7. Your rights: As a data subject you may apply to us in writing to learn whether your data is processed, request information, ask for correction or deletion, and exercise your other statutory rights.

Address for applications: ………………………
Contact: ………………………

……………………… Apartment/Complex Management — …/…/20…

Filling Guide

List the exact camera positions in the resolution. Vague wording such as "at suitable points" leaves the decision open to challenge.

Keep the retention period reasonable. In practice periods of no more than thirty days are preferred for security purposes; longer retention may breach the principle of proportionality.

Display the privacy notice on the noticeboard and, where possible, deliver it in writing to each unit. A short information sign should also be placed in areas covered by cameras.

After Installation

Access to recordings should be limited to an authorised person and logged. Sharing footage in messaging groups or on social media is a serious breach that attracts both administrative sanctions and liability in damages.

Where a resident requests footage after an incident, it should not be handed over directly; the request should be routed through the judicial authorities.

Common Mistakes

• Installing without a resolution: exposes the building to an action for prevention of interference.
• Angles showing unit doors: breaches the privacy of private life.
• No privacy notice or signage: this is an express statutory duty.
• Sharing footage in groups: counts as an unlawful transfer.
• Indefinite retention: breaches the principle of proportionality.

This content and these templates are for information only and are examples. Adapt them to your situation; seek expert advice if in doubt about personal data processes.