It is seen that, in distance learning platforms, personal data such as names and surnames of the students as well as some special categories of data that can be evaluated within the scope of biometric data such as voice and image, are processed.

Article 5 of Personal Data Protection Law No.6698 specifies the conditions for the processing of personal data and Article 6 of the same Law determines the conditions for special categories of personal data including biometric data. With regards to this, personal data should be processed in accordance with the conditions specified in Article 5 and/or Article 6 of the Law.

Furthermore, it is observed that much software that is used for distance learning provides services through cloud service providers and the data centers of such software are mostly located abroad. It should be noted that transfers that do not comply with the conditions set out in Article 9 of the Personal Data Protection Law may be in a violation of the Law, due to the fact that transfer of personal data abroad would come into question in case platforms with data centers abroad are used.

In this regard, "Personal Data Security Guide (Technical and Organisational Measures)" prepared by the Personal Data Protection Board and the Board Decision No. 2018/10 of 31/01/2018 on "Adequate Measures to be taken for the Processing Special Categories of Personal Data by Data Controllers" should be taken into consideration regarding whether these platforms used for distance learning services take necessary data security measures.