End to Personal Data Disclosure on Estate and Apartment Notice Boards: An Up-to-Date KVKK Guide for Managements

Mass housing, estates, and apartments where millions of citizens live together in Turkey are areas where legal obligations, as well as common living rules, must be meticulously applied. For years, the use of notice boards at building entrances by estate and apartment managements as an instrument of “announcement and disclosure” (hanging name lists, dues statuses, or personal warnings in a way that everyone can see) has been at the center of a legal debate.

The KVKK (Personal Data Protection Board) Principle Decision published in the Official Gazette dated March 31, 2026, and numbered 33210, along with the general provisions of the law, put a definitive end to these debates. Now, it is strictly forbidden to post not only debt lists but also residents’ names, apartment numbers, or other personal data on apartment notice boards.

Legal Basis and General Scope of the Decision

The Personal Data Protection Law (KVKK No. 6698) stipulates the condition of “compliance with the law and rules of good faith” in the processing of personal data. Estate managements bear the title of “Data Controller” within the scope of the law. They are obliged to protect the names, phone numbers, license plates, or financial data they collect from residents.

Principle of Proportionality and Data Minimization

At the core of the ban on lists posted on notice boards lies the principle of “proportionality” in data processing. The aim of an estate management may be to provide information or ensure collection; however, publicly displaying the names, surnames, or apartment numbers of residents to achieve this goal means legally crossing the line.

Public Nature of Common Areas

Building entrances, elevators, or corridors are areas accessible not only to those living in that building but also to cargo carriers, couriers, plumbers, and foreign third parties. Therefore, the display of a person’s identity or debt status in such areas constitutes unlawful data sharing of personal data and may be subject to administrative sanctions.

What is Strictly Forbidden to Post on Notice Boards?

A point where many people are mistaken is that the ban only covers debtors. However, under the KVKK, the information forbidden from being posted on notice boards without the person’s consent is quite extensive:

• Financial Information and Delay Periods: The amount of debt, the months it belongs to, or the person’s payment habits.
• Ownership Status: Status information regarding whether the relevant person is a homeowner or a tenant in that apartment.
• Vehicle License Plates: Posting the license plates of vehicles that parked incorrectly or do/do not belong to the estate by matching them with names.
• Name and Surname Lists: It is forbidden to post name-surname lists not only of debtors but even under the headings of “those who paid their dues” or “meeting attendees.”
• Apartment and Phone Numbers: Even if the name is not written, the apartment number or phone number cannot be used in notice board announcements as it makes the person “identifiable.”

How Should Notifications Be Made in the New Era?

These strict rules do not prevent managements from communicating or collecting their receivables; they only require the method to be placed on a legal basis. As Esenyel Partners, we advise the estate managements we consult to rapidly align their operational processes with the KVKK.

Lawful notification methods that should be used are as follows:

• Direct and Individual Communication: SMS messages sent directly to the relevant person’s mobile phone or information transmitted solely to their personal e-mail address.
• Closed and Private Communication Channels: WhatsApp groups closed to the outside and third parties, or professional estate management applications that only residents can log in to with a password.
• Physical Notifications with Ensured Privacy: If a physical notification is to be made, instead of posting it on the notice board, closed letters left in the person’s mailbox in a “sealed envelope” style with only the addressee’s name written on it.

Sanctions Awaiting Managements That Do Not Comply With the Rule

These rules are not recommendations; they are mandatory legal rules. Managements that do not change their practices and continue to post names or debt lists on notice boards will be investigated by the Personal Data Protection Board upon complaint.

Extremely high administrative fines, which are difficult to overcome, can be applied to managements (data controllers) on charges of failing to ensure data security and disclosing personal data. Furthermore, residents whose data is shared without permission will have the right to file lawsuits for pecuniary and non-pecuniary damages against the management.

The protection of personal data in estate and apartment managements is a very broad and sensitive issue ranging from notice boards to security cameras, from visitor logbooks to employees’ personnel files. It is essential for managements to conduct all these processes with professional steps in accordance with legal norms, not with amateur methods.

As Esenyel Partners, we stand by your side with our deep experience in the fields of real estate law, mass housing management, and the Personal Data Protection Law. You can contact us with our professional team to discuss all details related to the subject to make the current practices of your estate or apartment fully compliant with the law, have your risk analyses done, and protect against heavy administrative fines.