Our commitment to the protection of personal data: "Informed people and protected data"
The Management / Governing Body of Joaquín Denis Tremols (hereinafter, the data controller), assumes maximum responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, guaranteeing the continuous improvement of the data controller with the aim 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 regulations on the protection of personal data (Organic Law, specific sector legislation and its implementing regulations).
The Data Protection Policy of Joaquín Denis Tremols is based on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the regulatory and jurisprudential framework that governs said Policy, and is able to demonstrate this to the competent control authorities.
In this sense, the data controller will be governed by the following principles that should serve as a guide and frame of reference for all its staff in the processing of personal data:
- Data protection by design: the data controller will apply, both when determining the means of processing and at the time of the processing itself, technical and appropriate organizational measures, such as pseudonymization, designed to effectively implement data protection principles, such as data minimization, and to integrate necessary safeguards into the processing.
- Data protection by default: The controller shall implement appropriate technical and organizational measures to ensure that, by default, only personal data necessary for each specific purpose of the processing are processed.
- Data protection throughout the information lifecycle: Measures ensuring the protection of personal data shall apply throughout the full lifecycle of the information.
- Lawfulness, fairness and transparency: Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject.
- Purpose limitation: Personal data will be collected for specified, explicit and legitimate purposes and will not be further processed in a manner incompatible with those purposes.
- Data Minimization: Personal data will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- Accuracy: Personal data will be accurate and, where necessary, kept up to date; All reasonable steps will be taken to ensure that personal data that are inaccurate with respect to the purposes for which they are processed are promptly deleted or rectified.
- Retention period limitations: Personal data will be kept in a manner that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
- Integrity and confidentiality: Personal data will be processed in a way that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, through the application of appropriate technical or organizational measures.
- Information and training: One of the keys to ensuring the protection of personal data is the training and information provided to the personnel involved in the processing thereof. Throughout the information lifecycle, all personnel with access to the data will be appropriately trained and informed about their obligations regarding compliance with data protection regulations.
The Data Protection Policy of Joaquín Denis Tremols is communicated to all of the data controller's staff and made available to all interested parties.
Consequently, this Data Protection Policy involves all of the data controller's staff, who must be aware of it and accept it, considering it as their own. Each member is responsible for applying it and verifying the data protection regulations applicable to their activity, as well as identifying and providing any opportunities for improvement they deem appropriate in order to achieve excellence in compliance.
This Policy will be reviewed by the Management / Governing Body of Joaquín Denis Tremols as many times as deemed necessary, in order to comply, at all times, with the provisions in force regarding the protection of personal data.