Commitment to Personal Data Protection

The Management / Governing Body of ————–, S.L. (hereinafter, the data controller) assumes the highest level of responsibility and commitment to establishing, implementing and maintaining this Data Protection Policy, ensuring the continuous improvement of the data controller with the aim of achieving excellence in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), and with Spanish legislation on the protection of personal data (Organic Law, specific sectoral legislation and implementing regulations).

The Data Protection Policy of ——————-, S.L. is based on the principle of accountability, under which the data controller is responsible for complying with the regulatory and case-law framework governing this Policy and must be able to demonstrate such compliance to the competent supervisory authorities.

Accordingly, the data controller shall be governed by the following principles, which must serve as a guide and frame of reference for all staff when processing personal data:

  1. Data protection by design: both when determining the means of processing and during the processing itself, the data controller shall implement appropriate technical and organisational measures, such as pseudonymisation, designed to effectively apply data protection principles, such as data minimisation, and to integrate the necessary safeguards into the processing.
  2. Data protection by default: the data controller shall implement appropriate technical and organisational measures to ensure that, by default, only personal data that are necessary for each specific processing purpose are processed.
  3. Data protection throughout the information life cycle: measures designed to ensure the protection of personal data shall apply throughout the entire information life cycle.
  4. Lawfulness, fairness and transparency: personal data shall be processed lawfully, fairly and transparently in relation to the data subject.
  5. Purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes and shall not be further processed in a manner incompatible with those purposes.
  6. Data minimisation: personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  7. Accuracy: personal data shall be accurate and, where necessary, kept up to date; every reasonable step shall be taken to ensure that personal data that are inaccurate in relation to the purposes for which they are processed are erased or rectified without delay.
  8. Storage limitation: personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
  9. Integrity and confidentiality: personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
  10. Information and training: one of the keys to ensuring the protection of personal data is the training and information provided to personnel involved in processing such data. Throughout the information life cycle, all personnel with access to data shall receive appropriate training and information regarding their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of ——————, S.L. is communicated to all personnel of the data controller and made available to all interested parties.

Accordingly, this Data Protection Policy applies to all personnel of the data controller, who must be familiar with it and accept it as their own. Each member of staff is responsible for applying it and for verifying the data protection rules applicable to their activity, as well as for identifying and proposing any opportunities for improvement they consider appropriate with the aim of achieving excellence in compliance.

This Policy shall be reviewed by the Management/Governing Body of ——————, S.L. whenever deemed necessary in order to remain aligned at all times with the applicable personal data protection provisions.