Can You Legally Film a Wedding, House or Person with a Drone in Turkey?

A drone flying over a wedding venue can create spectacular cinematic footage. A real estate agency can show an entire villa, garden and coastline in a thirty-second aerial video. Hotels, construction companies, event organisers and social-media agencies increasingly use drones as ordinary commercial photography tools.

Yet a drone with a camera is legally much more than a flying camera.

Consider a wedding photographer who has been hired to produce an aerial wedding video. The drone is lawfully operated by a qualified pilot and the required aviation permission has been obtained. During the flight, however, the camera also records hundreds of wedding guests, employees of the venue, neighbouring properties and people walking outside the event area.

Is the footage lawful simply because the drone flight itself was authorised?

The answer is no.

Turkish law requires at least three separate questions to be considered:

Was the drone legally permitted to fly?

Was the recording of the people or property lawful?

Can the resulting footage legally be published, transferred, advertised or uploaded to social media?

These questions are governed by different legal regimes.

The flight itself falls primarily within Turkish aviation law and the rules of the Directorate General of Civil Aviation (SHGM). Images of identifiable individuals may fall within Law No. 6698 on the Protection of Personal Data (KVKK). More intrusive filming may also engage the constitutional right to privacy, personality rights under Turkish private law and, in serious cases, criminal provisions concerning the violation of private life.

This distinction has become even more significant following Turkey’s new SHT-İHA Instruction on Unmanned Aircraft Systems, published on 30 July 2026. The new regime expressly refers to the KVKK among its statutory bases and introduces a substantially revised system of drone classes, pilot licences, geographic restrictions and operational authorisations.

The central legal principle can therefore be stated simply:

Permission to fly is not permission to film, and permission to film is not automatically permission to publish.

1. The New Turkish Drone Law Framework in 2026

The regulatory environment for civilian drones in Turkey changed significantly in July 2026.

The current SHT-İHA, published by the SHGM on 30 July 2026, regulates civilian unmanned aircraft systems operated in Turkish airspace. Its scope covers matters including registration, licensing, airworthiness, pilot qualifications, flight permissions, operational safety and airspace management.

Significantly for drone photography, the new Instruction expressly identifies Law No. 6698 on the Protection of Personal Data as one of its legal bases. It also defines restricted areas as airspace that may be restricted or prohibited for reasons including safety, security and privacy.

This represents an important conceptual development.

Drone regulation is no longer viewed merely as a question of whether an aircraft may safely occupy a particular part of the sky. Privacy and data protection are increasingly part of the regulatory architecture surrounding drone operations.

2. Drone Weight Is No Longer the Only Question

Under the new SHT-İHA regime, unmanned aircraft are classified primarily into four mass categories:

M0 covers aircraft from 500 grams up to 4 kilograms; M1 covers 4 to 25 kilograms; M2 covers 25 to 150 kilograms; and M3 applies to aircraft weighing 150 kilograms or more.

However, an important distinction now exists for very small drones.

The Instruction recognises a narrow category of “Simple UAS”, essentially an aircraft technically restricted to a very small flight envelope. Such aircraft benefit from exemptions relating to licensing, registration, aircraft registration and import approval.

But a drone weighing less than 500 grams is not automatically outside the regulatory system. The new Instruction expressly provides that an aircraft below 500 grams which does not satisfy the definition of a Simple UAS is subject to the M0 regime.

This is particularly relevant to consumer camera drones.

The assumption that “my drone is under 500 grams, therefore aviation law does not apply” can no longer safely be made under the current regime.

3. Commercial Filming Changes the Regulatory Position

The legal position also depends on the nature of the operation.

The new system distinguishes between P0, P1 and P2 pilot licensing levels.

A P0 licence concerns non-commercial, amateur operations within defined VLOS limits.

A P1 licence applies to commercial operations. Under the current framework, P1 operations are generally conducted within visual line of sight and within the flight envelope established by the Instruction.

A P2 licence applies to substantially higher-risk operations, including BVLOS operations, autonomous operations and flights involving crowds or persons, as well as certain transport operations.

This distinction immediately affects ordinary photography businesses.

A person flying a drone privately during a countryside trip is in a very different regulatory position from a company providing:

“Professional Drone Wedding Package – €1,000”

or:

“Luxury Property Aerial Photography Service.”

Once the operation is conducted commercially, the operator must examine the licensing and operational requirements applicable to commercial activity.

And where the proposed footage requires the drone to operate over a dense wedding crowd, concert audience or similar gathering, the legal issue becomes more serious because the new regime expressly treats crowd and human overflight as P2-level high-risk activity.

4. A Wedding Drone Is Not Automatically Legal Because the Bride and Groom Agreed

Wedding filming provides one of the best examples of the interaction between aviation law and privacy law.

Suppose a couple enters into a contract with a professional production company.

The couple expressly agrees to:

• aerial video recording,
• editing of the wedding film,
• delivery of the final video,
• use of selected images in the photographer’s portfolio.

That contractual relationship may provide an important legal basis for processing the couple’s own data.

But the wedding may include 250 other individuals.

Those guests are not parties to the photography agreement.

Their presence at the wedding cannot automatically be treated as unlimited authorisation for a photographer to use identifiable images of them for every subsequent purpose.

There is therefore an important difference between:

filming the event for delivery to the couple

and

using close-up footage of wedding guests in an Instagram advertisement promoting the photography company.

The first activity may potentially be assessed through contractual necessity, legitimate interests or other applicable KVKK grounds depending on the circumstances.

The second involves a new commercial marketing purpose and will normally require a separate and much more careful legal analysis.

5. Is a Person’s Image “Personal Data” Under the KVKK?

Yes, where the individual is identified or identifiable.

The Turkish Personal Data Protection Authority defines personal data broadly as any information relating to an identified or identifiable natural person. It also explains that obtaining, recording, storing, disclosing, transferring and making such data available constitute forms of personal-data processing.

Accordingly, a drone recording may contain personal data where individuals can be recognised from:

their faces, physical characteristics, clothing combined with context, vehicle registration information, location, behaviour or other identifying circumstances.

A wide aerial shot in which individuals appear merely as indistinguishable dots may create a different legal assessment.

By contrast, a low-altitude 4K recording showing a person’s face while entering their home clearly presents a much stronger personal-data and privacy issue.

The legal assessment therefore depends not simply on whether “people appear somewhere in the frame” but on whether those individuals are identified or reasonably identifiable.

6. A Photograph Is Not Automatically Biometric Data

This distinction is also important.

An ordinary image of a face is generally personal data, but it does not automatically become biometric data merely because the person’s face is visible.

The Turkish Personal Data Protection Board has recognised that facial imagery becomes biometric data where it is subjected to specific technical processing for the purpose of uniquely identifying or verifying an individual, such as through a facial-recognition system.

Therefore, an ordinary drone wedding video and an AI-powered drone system automatically identifying every guest by facial recognition raise very different data-protection risks.

The latter may involve special-category biometric data and considerably stricter legal requirements.

7. Does Every Person Filmed by a Drone Have to Give Explicit Consent?

Not necessarily.

A common misunderstanding of the KVKK is that every processing activity requires explicit consent.

Article 5 of the KVKK provides a number of lawful bases in addition to explicit consent.

Depending on the specific circumstances, processing may potentially rely on grounds including:

performance of a contract where the data relates directly to a party to that contract;

compliance with a legal obligation;

establishment, exercise or protection of a legal right;

data made public by the individual;

or the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the individual are not prejudiced.

The correct legal question is therefore not:

“Do we have consent from everyone?”

It is:

“What is the lawful basis for this particular processing activity, involving this particular individual, for this particular purpose?”

If no other lawful basis exists, explicit consent may become necessary.

And where consent is relied upon, it must be specific, informed and freely given.

8. The Purpose of the Recording Matters

The same video can be lawful for one purpose and unlawful for another.

Imagine that a drone company records a wedding because it has been hired to produce the couple’s wedding film.

The company then stores the original footage.

Six months later, it extracts a particularly attractive scene showing several guests and uses it in:

a television advertisement, an Instagram campaign and a promotional video displayed at a wedding exhibition.

The purpose of processing has changed.

Originally, the footage was created to perform a wedding-video service.

It is now being used to market the drone company.

Under the KVKK, personal data must be processed for specific, explicit and legitimate purposes and must remain relevant, limited and proportionate to those purposes.

A contractual basis supporting the original recording does not automatically justify unlimited future advertising use.

9. Real Estate Drone Photography: What About the Neighbour’s Garden?

Real estate photography produces a different but equally common privacy problem.

Imagine an estate agency is instructed to produce aerial footage of a luxury villa.

The owner consents.

The drone ascends above the property and records:

the villa, swimming pool, garden and surrounding neighbourhood.

However, the footage also clearly reveals the neighbouring property’s garden.

A person is sunbathing beside the neighbour’s swimming pool.

The fact that the drone was legally flying above the seller’s property does not automatically give the estate agent a legal right to record and publish the neighbour’s private activities.

The legal risk becomes particularly serious where technological capability allows the drone operator to observe an area that a person could reasonably expect to remain private.

A drone can see over walls, fences, hedges and high floors that normally protect individuals from ordinary observation from the street.

That is precisely why aerial photography can create a qualitatively different privacy interference from ordinary street photography.

10. “But the Person Was Outside” Is Not a Complete Defence

Being outdoors does not necessarily mean that a person has abandoned all expectation of privacy.

There is an obvious difference between filming:

a pedestrian walking through a busy public square

and

a person spending time on the secluded terrace of their private residence.

The Turkish Criminal Code protects the confidentiality of private life.

Article 134 provides criminal sanctions for violation of an individual’s private-life confidentiality and treats recording by image or sound as an aggravated form of interference. The unlawful disclosure of images or sounds relating to private life is separately punishable.

Accordingly, a drone operator should not assume:

“If my drone can physically see it, I can legally record it.”

Technical visibility and legal permissibility are different concepts.

11. Drone Footage Can Create Criminal Liability

The most serious cases can move beyond KVKK administrative liability and civil damages.

Article 134 of the Turkish Criminal Code concerns violations of private life.

Article 135 criminalises the unlawful recording of personal data.

Article 136 regulates unlawfully giving, disseminating or obtaining personal data.

The legal characterisation will depend heavily on the circumstances.

For example, secretly hovering a camera drone beside a residential window in order to record the occupants presents a completely different criminal-law risk from inadvertently capturing a passer-by in the background of a city panorama.

Intent, location, expectation of privacy, the nature of the image, persistence of surveillance and subsequent distribution may all become important.

12. Recording and Publishing Are Two Different Acts

One of the most important rules for commercial drone operators is that obtaining footage and publishing footage should be analysed separately.

Suppose a drone unintentionally captures a recognisable person for three seconds.

The operator later reviews the footage.

At that stage, there may be several options:

blur the person’s face;

crop the scene;

remove the sequence;

retain it only for the agreed production purpose;

or publish it publicly.

The privacy implications of those choices are different.

Uploading the footage to:

Instagram, TikTok, YouTube, a hotel website, an estate agency listing or an international stock-footage platform

may constitute additional use, disclosure or transfer of personal data.

Publication therefore requires its own legal basis and proportionality analysis.

13. The KVKK Information Obligation Still Matters

Where the KVKK applies, identifying a lawful basis for processing is not the end of the matter.

Article 10 imposes a separate information obligation on the data controller.

The person whose data is processed must generally be informed about matters including:

the identity of the controller, the purpose of processing, recipients and transfer purposes, the method and legal basis of collection and the individual’s statutory rights.

The Turkish Personal Data Protection Board has recently emphasised this distinction again.

In its 2026 principle decision, the Board stressed that privacy notices and explicit-consent mechanisms are legally different concepts and, where consent is used, they should be structured separately rather than combined into one ambiguous document.

For professional wedding, event and production businesses, this makes the design of booking documents and event notices particularly important.

14. How Can a Wedding Company Inform Hundreds of Guests?

In large events, individually negotiating privacy terms with every person before every camera shot may be impractical.

That does not mean that data-protection obligations simply disappear.

A professionally designed event may use a layered transparency model.

For example, guests could be informed in advance through the invitation or event website that photography and drone recording will occur. Clear notices may also be placed at entrances, and information may explain the identity of the relevant data controller, purposes of processing and how guests can raise concerns.

This does not automatically solve every legal issue, nor does a sign stating:

“By entering you consent to everything.”

necessarily create valid unlimited consent.

But effective transparency can substantially improve compliance, particularly where combined with careful camera positioning, avoidance of intrusive close-ups, dedicated no-filming areas and an appropriate lawful basis.

15. Children Require Special Care

Drone filming at weddings, hotels, schools, sports events and festivals frequently captures children.

This creates enhanced legal risk.

Children may be less able to understand the implications of publication, and commercial use of identifiable children’s images should therefore be approached conservatively.

A wedding video delivered privately to the family and an advertisement showing an identifiable child on a company’s social-media account are not equivalent forms of processing.

Commercial drone operators should therefore adopt specific procedures for footage involving minors, particularly where images will be used beyond the immediate event-production purpose.

16. What About Purely Personal Drone Use?

The KVKK contains a limited household/personal-activity exemption.

The Personal Data Protection Authority explains that processing performed by a natural person entirely in relation to themselves or family members living in the same household may fall outside the KVKK, provided the data is not disclosed to third parties and data-security requirements are respected.

The Authority uses private family photographs as an example, but notes that making such material publicly available may remove the benefit of the exemption.

This means that filming a private family event for private family use may occupy a different legal position from operating a professional wedding-photography business.

However, even where the KVKK exemption applies, this does not amount to a general licence to violate another person’s private life.

Criminal-law protections and civil personality rights remain relevant.

17. A Legal Drone Flight Can Still Be an Unlawful Recording

This is probably the most important practical point.

Suppose a company obtains every required aviation authorisation.

The pilot holds the correct licence.

The aircraft is properly registered.

The flight takes place within the authorised area.

The aviation operation may therefore be perfectly lawful.

Nevertheless, if the drone is deliberately positioned outside an apartment window and records a person inside their home, obtaining the flight authorisation does not legalise the recording.

Conversely, consent from a property owner to film their home does not legalise an otherwise unauthorised flight in restricted airspace.

The two regimes operate independently.

Aviation permission governs access to the airspace.

Privacy and data-protection law govern what may lawfully be observed, recorded, stored and used.

A professional operator must comply with both.

18. The New Green, Orange and Red Area System

The 2026 SHT-İHA establishes a new geographic model under the İHATTYS – Unmanned Aircraft Tracking and Traffic Management System.

Turkish airspace is divided for drone purposes into green, red and orange areas together with areas falling outside those classifications.

Green areas permit operations under specified altitude and operational conditions without an additional operational permission.

Red areas are closed or restricted areas where operations require the approval of the relevant authority and SHGM authorisation.

Orange areas reflect areas for which an existing flight authorisation or allocated airspace volume exists.

Importantly, areas outside the defined green, red and orange categories are also treated as restricted under the Instruction and generally require authorisation.

The system is therefore more sophisticated than the common assumption that a pilot can simply open a drone application, see no manufacturer warning and begin flying.

Manufacturer geofencing is not a substitute for compliance with Turkish aviation law.

19. Privacy Can Affect Airspace Classification Itself

An especially interesting feature of the new SHT-İHA is that privacy is expressly incorporated into airspace regulation.

The Instruction states that restricted areas may exist for safety, security or privacy reasons and that the determination of green areas may take privacy considerations into account.

This demonstrates an important shift in modern drone law.

Traditionally, aviation law answered questions such as:

“Will this aircraft collide with another aircraft?”

Drone law must now also ask:

“Should this aircraft be permitted to operate in a location where its sensors create privacy risks for people on the ground?”

The aircraft and the camera can no longer be regulated as entirely separate technologies.

20. Crowd Filming Requires Particular Caution

A drone video showing a wedding, music festival or sporting event may look harmless from a marketing perspective.

From an aviation-law perspective, however, a large crowd substantially increases the consequences of a technical failure.

The new SHT-İHA therefore places crowd and human overflight within the P2 high-risk category rather than ordinary commercial P1 operations.

Accordingly, a wedding videographer should not assume that a P1 commercial qualification automatically authorises hovering directly above hundreds of guests.

The exact flight path matters.

Filming a venue from a safe peripheral position and flying directly above a dense group of people are legally different operations.

21. Commercial Real Estate Advertising Creates a Second Layer of Risk

Real estate agencies increasingly use drone videos on:

property portals, Instagram, YouTube, foreign-language websites and international advertising networks.

This creates two separate stages of legal analysis.

First, the drone operation itself must comply with aviation rules.

Second, the agency must review the finished footage for personal-data and privacy issues before publication.

Problematic material may include:

recognisable neighbours, vehicle registration plates, children playing in neighbouring properties, activities inside adjacent homes, private balconies, security arrangements or other information unrelated to the property being marketed.

The KVKK’s principle of proportionality is particularly relevant here.

If the purpose is to advertise Villa A, continuously recording the private life of the occupants of Villa B is unlikely to be necessary for that purpose.

22. Filming Public Streets Is Not Automatically Unrestricted

A commercial drone may also capture people on streets, beaches or public squares.

Public location is relevant because an individual’s reasonable expectation of privacy is generally lower than inside a home.

But public presence does not remove all protection under personal-data law.

Where identifiable individuals are deliberately recorded, followed, profiled or made the subject of promotional footage, the operator must still identify an appropriate legal basis and comply with the general KVKK principles.

The Turkish Personal Data Protection Board has emphasised in the camera-surveillance context that even where legitimate interests may support camera use, camera positioning cannot disproportionately interfere with individuals’ legitimate expectations of privacy.

The same proportionality logic is highly relevant to drone cameras.

23. What If the Drone Records Sound?

Many commercial drone systems primarily capture video, but additional devices or ground equipment may also collect audio.

Audio recording creates separate risks.

Article 133 of the Turkish Criminal Code contains specific rules concerning the recording of non-public conversations, while Article 134 protects private-life images and sounds.

A drone operator should therefore be especially cautious where technology permits the capture of conversations that the participants reasonably regarded as private.

The fact that a microphone can technically capture a conversation does not create a legal right to record it.

24. Social Media Is Often Where the Real Legal Problem Begins

Many disputes do not arise because footage was recorded.

They arise because it was published.

A wedding photographer may record 200 guests without receiving any objection during the event.

The dispute may begin several days later when an identifiable guest discovers that their image has been used in a sponsored Instagram advertisement.

Similarly, a neighbour may tolerate a drone passing nearby but object when footage of their garden appears on an international property website.

Commercial operators should therefore distinguish between at least three levels of use:

internal raw footage, contractual delivery to the customer and public promotional publication.

Each level may require a different legal justification.

25. Drone Footage Stored in the Cloud Creates Additional Questions

Professional video files are rarely kept only on the pilot’s memory card.

They may be uploaded to:

cloud storage, editing platforms, international production software or file-transfer services.

Where personal data is transferred to infrastructure outside Turkey, the rules governing international transfer of personal data under the KVKK must also be considered.

This issue is particularly relevant to modern production companies using global cloud infrastructure.

The legal analysis should therefore not stop when the drone lands.

The full lifecycle of the footage matters:

capture → storage → editing → sharing → publication → archiving → deletion.

26. Data Security Is Part of Drone Compliance

Article 12 of the KVKK requires data controllers to take appropriate technical and organisational measures to prevent unlawful processing and access and to ensure the protection of personal data. The Personal Data Protection Board repeatedly treats these security obligations as an essential part of lawful processing.

For drone businesses this may involve protecting:

memory cards, laptops, cloud accounts, editing systems, customer portals and archived raw footage.

A wedding-production company holding hundreds of hours of private footage should therefore treat those recordings as valuable personal-data assets rather than ordinary video files.

27. How Long Can Drone Footage Be Kept?

The KVKK requires personal data to be retained only for the period provided by applicable legislation or necessary for the purpose for which the data was processed.

A production company should therefore be able to explain why it retains raw footage.

For example, temporary retention may be justified for editing, customer revisions, backup and potential contractual disputes.

Indefinitely preserving every raw drone recording “because storage is cheap” is far more difficult to reconcile with the data-minimisation and retention principles.

Retention schedules should therefore form part of professional drone businesses’ KVKK compliance programmes.

28. Who Is the Data Controller: The Client or the Drone Company?

This question can become legally complex.

Suppose a hotel hires an independent production agency to produce a promotional drone video.

The hotel decides:

what will be filmed, why it will be filmed and how the finished material will be used.

The production company operates the aircraft and processes the footage on the hotel’s instructions.

Depending on the contractual and practical structure, the hotel may act as the data controller, while the production company may operate as a processor.

In another transaction, however, the drone company may independently determine additional purposes—for example, retaining footage to build its own commercial stock-video library.

For that separate activity, it may itself become a data controller.

Legal status therefore depends on who actually determines the purposes and means of processing, rather than simply what title is written in the contract.

29. Contracts Between Clients and Drone Operators Should Address Privacy

A professional drone-services agreement should not regulate only:

flight date, duration, price and number of edited videos.

It should also allocate legal responsibilities relating to the filming itself.

A well-drafted agreement should address matters such as who determines the filming areas, who obtains aviation permissions, who provides event or property access, who is responsible for privacy notices, the permitted purposes for which footage may be used, whether promotional portfolio use is allowed, retention periods, confidentiality, security, subcontractors, deletion obligations and responsibility for third-party claims.

This is particularly important because a client may say:

“You can use the wedding video for your portfolio.”

But the client cannot necessarily provide unlimited consent on behalf of every identifiable third party appearing in that video.

30. The 2026 Regulatory Transition Period Must Also Be Considered

The new SHT-İHA entered into force upon publication on 30 July 2026 and repealed the previous 2016 Instruction.

However, the new system contains extensive transitional provisions.

Existing aircraft, licences and authorisations are given transition periods extending in several respects to 31 July 2027. The Instruction also provides that until the new İHATTYS system becomes operational for the relevant procedures, certain processes under the previous framework may continue to be used.

This makes the current period particularly important for commercial operators.

A business relying on information learned several years ago about the former İHA0/İHA1 regime should not assume that those rules continue unchanged.

The 2026 regime introduces the new:

M0–M3 aircraft classifications and P0–P2 pilot licensing structure.

31. What Can Happen If the Aviation Rules Are Violated?

The new SHT-İHA provides that violations may result in sanctions under the Turkish Civil Aviation Act and the regulation governing administrative fines imposed by the SHGM.

The SHGM may also restrict, suspend or cancel operational authorisations and pilot licences in appropriate circumstances.

Depending on the seriousness and repetition of violations, pilot licences may be suspended, and intentional or grossly negligent violations of flight safety can result in cancellation.

A professional drone operator therefore faces more than the risk of simply being asked to land the aircraft.

Repeated non-compliance can affect the operator’s ability to continue conducting commercial operations.

32. What Can Happen If Privacy Rules Are Violated?

Privacy-related consequences may arise simultaneously under several legal regimes.

A single incident can potentially lead to:

KVKK proceedings and administrative sanctions;

civil claims based on violation of personality rights;

claims for compensation;

requests for removal or deletion of footage;

criminal investigation where the conduct reaches the threshold of offences concerning private life or personal data.

The availability of one remedy does not necessarily exclude the others.

A drone recording unlawfully obtained and then published online can therefore create considerably greater exposure than an ordinary aviation-law violation.

33. Four Everyday Examples

Wedding Filming

A professional drone operator is hired to create a wedding film.

The operation is commercial and must therefore satisfy the aviation requirements applicable to commercial operations. Flying directly above a dense group of guests may move the operation into the P2 high-risk regime.

The couple’s agreement does not automatically authorise unlimited commercial use of every guest’s identifiable image.

The company should separately analyse event transparency, processing grounds and promotional publication.

Luxury Villa Advertisement

The property owner authorises aerial filming.

The drone may legally record the property being sold, but the owner’s permission does not automatically authorise intrusive recording of neighbours.

Footage should be reviewed before publication, and unnecessary identifiable third-party material should normally be removed, blurred or excluded.

Hotel Promotion

A hotel hires a production company to record the swimming pool and beach.

Guests appear in the footage.

The hotel must determine a lawful data-processing basis and satisfy its transparency obligations. Using close-up footage of individual guests in a commercial advertising campaign presents significantly greater risk than wide shots in which individuals cannot be identified.

Social-Media Content Creator

A creator launches a drone in a permitted area and records people on the beach.

The flight may be aviation-law compliant.

But repeatedly tracking a specific identifiable individual, zooming into private behaviour and publishing the recording to millions of followers raises separate privacy, personal-data and potentially criminal-law issues.

34. A Practical Compliance Test Before Drone Filming

Before a commercial drone photography operation in Turkey, the operator should ask:

• Is the aircraft and user compliant with the new 2026 SHT-İHA regime and applicable transition rules?
• Does the pilot hold the correct P0, P1 or P2 level for the proposed operation?
• Is the location green, orange, red or otherwise restricted under the relevant SHGM system?
• Is separate flight authorisation required?
• Will the flight pass over crowds or persons?
• Will identifiable individuals be recorded?
• What is the KVKK lawful basis for that recording?
• Has the required privacy information been provided?
• Is explicit consent genuinely necessary, and if used, is it specific and freely given?
• Will the footage later be used for advertising or social media?
• Are children or private residential areas likely to appear?
• Will footage be transferred to cloud or editing systems outside Turkey?
• How long will raw footage be retained?
• Can unnecessary people, number plates or private areas be blurred or removed?
• Does the service agreement properly allocate aviation, privacy and data-protection responsibilities?

Conclusion: A Drone Has Two Legal Functions—It Flies and It Observes

Drone law sits at the intersection of aviation regulation and information law.

The first function of a drone is obvious:

it flies through airspace.

For that reason, it is governed by aviation rules concerning aircraft classification, pilot competency, operational authorisation, restricted areas and flight safety.

But a camera-equipped drone performs a second function:

it observes people and places from a perspective that ordinary human observation may not reach.

That second function activates an entirely different legal framework.

Under Turkish law, images of identifiable persons may constitute personal data. Processing them requires compliance with the KVKK’s lawful-basis, transparency, proportionality, security and retention rules. Intrusive recording may additionally interfere with personality rights and, in sufficiently serious circumstances, constitute offences relating to private life or personal data.

The new Turkish SHT-İHA regime published on 30 July 2026 makes this relationship even clearer. The Instruction expressly refers to the KVKK as part of its legal basis and recognises privacy as a factor capable of justifying restrictions on drone airspace operations.

For wedding photographers, real estate companies, hotels, construction companies, advertising agencies and social-media creators, the central legal question should therefore never be limited to:

“Am I allowed to fly the drone here?”

Two additional questions must immediately follow:

“Am I legally entitled to record what the camera can see?”

and:

“Even if I can lawfully record it, am I entitled to publish and commercially exploit that footage?”

In modern drone operations, obtaining the answer to all three questions is what separates a technically successful flight from a legally compliant one.