Commitment to the Protection of Personal Information

D. RAFAEL SÁNCHEZ ARAÑA (hereinafter the data controller), takes on the highest degree of responsibility and commitment to establishing, implementing and maintaining this Data Protection Policy, guaranteeing continuous improvement as data controller with the objective of achieving excellence in relation to 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, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJEU L 119/1, 04-05-2016); and the Spanish legislation on personal data protection (Organic Law, sector-specific legislation and implementing provisions).

The Data Protection Policy of is built on the principle of proactive responsibility, according to which the data controller is responsible for complying with the regulatory framework which governs said Policy and is capable of demonstrating this to the competent control authorities.

In this regard, the data controller will be governed by the following principles, which must serve as a guide and frame of reference for all personnel for the processing of personal data:

  1. Data protection by design: the controller shall, both at the time of the determination of the means for processing and at the time of the processing itself, implement appropriate technical and organisational measures, such as pseudonymisation, which are designed to implement data-protection principles, such as data minimisation, in an effective manner and to integrate the necessary safeguards into the processing.
  2. Data protection by default: the controller shall implement appropriate technical and organisational measures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed.
  3. Data protection in the information life cycle: measures that guarantee the protection of personal data will be applicable throughout the entire information life cycle.
  4. Lawfulness, fairness and transparency: personal data will be processed lawfully, fairly and transparently in relation to the data subject.
  5. Purpose limitation: personal data will only be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
  6. Data minimisation: personal data will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  7. Accuracy: personal data will be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard 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 guaranteeing the protection of personal data is the training and information provided to the personnel involved in its processing. During the information life cycle, all personnel with access to data will be properly trained and informed about their obligations in relation to compliance with data protection regulations.

The Data Protection Policy is communicated to all of the data controller’s personnel and made available to all data subjects.

Consequently, this Data Protection Policy involves all of the data controller’s personnel, who must be aware of and follow it, considering it as their own, with each member of personnel being responsible for applying the Policy, verifying the data protection regulations applicable to their activity, and identifying and contributing the improvement opportunities they consider appropriate with the aim of achieving excellence in relation to compliance.

This Policy will be reviewed by THE DATA CONTROLLER, as often as necessary to ensure that it conforms at all times to the personal data protection provisions in force.