DeepManage

MDM Guide

MDM and data protection: GDPR and Türkiye's KVKK

An MDM system processes personal data about the people who carry managed devices. Data protection law does not forbid this, but it sets rules on what you collect, why, for how long and how you tell people about it.

6 min read · Updated:

Why device management is a data protection topic

A managed phone is usually carried by one person. Its serial number, its location, the apps on it and the logs it sends can all be linked to that person. Under GDPR and Türkiye’s Personal Data Protection Law (KVKK, Law No. 6698), this makes them personal data.

When your organization manages these devices, it decides why and how the data is processed. That makes it the data controller. If you use a cloud MDM, the vendor that hosts the data usually acts as a data processor on your behalf, and the two of you need a written agreement that sets out the processor’s duties.

This page is general information to help you ask the right questions. It is not legal advice; have your legal team or data protection officer review your own setup.

The principles both laws share

GDPR (Article 5) and KVKK (Article 4) are built on very similar principles. For an MDM project, five of them matter most:

  • Lawfulness and fairness: process data on a valid legal basis and in a way employees would reasonably expect.
  • Purpose limitation: decide in advance why you collect each type of data, and do not reuse it for unrelated purposes.
  • Data minimisation: collect only what the purpose needs. KVKK words this as data being “relevant, limited and proportionate”.
  • Storage limitation: keep data only as long as necessary, then delete or anonymise it.
  • Security: protect the data with appropriate technical and organizational measures (GDPR Article 32, KVKK Article 12).

Informing employees

Both laws require you to tell people about the processing before or when it starts. Under KVKK this is the duty to inform (aydınlatma yükümlülüğü, Article 10). Under GDPR it is the information duty in Articles 13 and 14.

A good information notice for managed devices covers:

  • who the data controller is
  • which data the MDM collects on each type of device (for example inventory, app list, location, logs)
  • why each type is collected and on which legal basis
  • who can see it inside the organization, and which service providers process it
  • where it is stored, including any transfer abroad
  • how long it is kept
  • the employee’s rights and how to use them

Show the notice at the moment it matters: when the device is handed over or enrolled. Keep a record that the employee received it.

Consent is often the first idea, and often the wrong one. In an employment relationship the employee may not feel free to refuse, so regulators on both sides are cautious about relying on consent. Under KVKK, explicit consent is one basis among several, and the Personal Data Protection Authority’s guidance indicates that it should not be used where another basis applies.

Other bases usually fit device management better:

  • Performance of a contract: managing the device the employee needs to do the job.
  • Legal obligation: for example security measures the organization is required to take.
  • Legitimate interests: protecting company data, recovering lost devices, keeping devices working. This requires a balancing test against the employee’s rights.

Decide the basis per type of data. Inventory and security status may rest on one basis; continuous location tracking needs a much stronger justification.

Data minimisation in practice

Minimisation is where MDM configuration and law meet. Questions to ask for each data type:

  • Location: Do we need it on every device, or only on field and high-risk devices? Do we need a continuous trail, or only on demand when a device is lost? Can collection stop outside working hours?
  • Call history and network logs: Is there a specific security or legal reason? If not, leave them off.
  • App inventory: On a company device this is normally needed. On a personal device with a work profile, limit it to work apps.
  • Screen viewing and remote control: Use it for support, with the user’s knowledge, and record who started each session.

Then set retention periods and make sure old data is actually deleted.

What an employer can and cannot see

The answer depends on the device’s ownership model. Our guide to device ownership models explains the modes in detail.

Company-owned, fully managed Personal device with work profile
Device model, OS version, security status Yes Yes
Apps installed All apps Work profile apps only
Location Possible, if enabled by policy Generally not available from the personal side
Call history, network logs Possible on some products, if enabled by policy Not from the personal side
Remote wipe Whole device Work profile only
Personal messages, photos, browsing content No, MDM is not built to read them No

The table shows typical behaviour. Check what your product actually collects in each mode, and write it into your notice.

Data residency and transfers abroad

Where the data is stored matters under both laws. GDPR restricts transfers outside the European Economic Area unless there is an adequacy decision or appropriate safeguards such as standard contractual clauses.

KVKK Article 9 was substantially amended in 2024. Transfers abroad can now rely on an adequacy decision, on appropriate safeguards such as standard contracts approved by the Authority, or on limited exceptions. Standard contracts must be notified to the Authority within five business days of signing.

For an MDM this means one practical question: where are the servers, and does the vendor use subcontractors in other countries? Keeping the MDM inside Türkiye, or inside your own facility, removes most transfer questions. The comparison in cloud vs on-premises MDM covers this choice.

Security measures your MDM should support

Data protection is also about protecting the data you hold. Look for:

  • role-based access, so each admin sees only the devices and data their job requires
  • integration with your directory, such as LDAP, for central account control
  • records of admin actions and remote sessions
  • encryption of data in transit and on the device
  • remote lock and wipe for lost devices

Our security and compliance page shows how these work in practice.

How DeepManage does it

DeepManage lets you decide per policy whether a device sends location, call history and network logs, so you collect only what each group needs. Organizations can publish their own terms of use in the console. Users see them on the device, and DeepManage keeps a record of who accepted which version on which device. Admin access is controlled through roles, organizational units and LDAP integration.

For data residency, DeepManage runs either in the cloud hosted by Infoline or on-premises in your own network, including closed networks. See location and geofencing and reports for what each feature collects.

Frequently asked questions

Do we need employee consent to manage company devices?

Usually consent is not the best basis. Both GDPR and KVKK recognise other legal bases, such as legal obligations, the employment contract and legitimate interests. Consent in an employment relationship is often not considered freely given. Decide the basis for each type of data with your legal team.

Can an employer read messages on a managed phone?

An MDM is not designed to read personal messages, emails or photos. What it can collect depends on the product and on the device mode. Some products can collect call history or network logs, which is personal data and needs a clear purpose, a legal basis and an information notice.

Is location tracking of employees allowed?

It can be, for a specific and legitimate purpose such as field safety, theft recovery or dispatching, and in proportion to that purpose. Tracking outside working hours or without telling employees is very hard to justify. Collect location only on the devices and at the frequency the purpose requires.

Does on-premises MDM make us KVKK or GDPR compliant?

No single tool makes you compliant. On-premises deployment helps with data residency and access control, but you still need a legal basis, an information notice, retention rules and security measures.

What about personal phones used for work?

Use a work profile. It separates work apps and data from personal ones, and the organization manages only the work side. This greatly reduces the personal data the employer can see.

See DeepManage on your own devices

Tell us about your fleet and we will prepare a demo environment for your team.