The Management / Governing Body of DOMINGO ALONSO GROUP, S.L. (hereinafter, the data controller) assumes the highest level of responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, ensuring 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) (OJ EU L 119/1, 04-05-2016), and Spanish personal data protection legislation (Organic Law, specific sectoral legislation and its implementing regulations).
The Data Protection Policy of DOMINGO ALONSO GROUP, S.L. is based on the principle of proactive accountability, according to which the data controller is responsible for compliance with the regulatory and case-law framework governing this Policy and is able to demonstrate such compliance to the competent supervisory authorities.
In this regard, the data controller shall be governed by the following principles, which shall serve all its personnel as a guide and reference framework when processing personal data:
1. Data protection by design: the data controller shall implement appropriate technical and organisational measures, such as pseudonymisation, both when determining the means of processing and during the processing itself, designed to effectively implement 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 purpose of processing are processed.
3. Data protection throughout the information life cycle: measures ensuring the protection of personal data shall apply throughout the entire life cycle of the information.
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 which 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, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by means of 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 the data shall receive appropriate training and information regarding their obligations to comply with data protection legislation.
The Data Protection Policy of DOMINGO ALONSO GROUP, S.L. is communicated to all personnel of the data controller and made available to all interested parties.
Consequently, this Data Protection Policy applies to all personnel of the data controller, who must be aware of it and accept it, considering it their own. Each member is responsible for implementing it and verifying the data protection rules applicable to their activities, as well as identifying and proposing any opportunities for improvement they deem appropriate, with the aim of achieving excellence in compliance.
This Policy shall be reviewed by the Management / Governing Body of DOMINGO ALONSO GROUP, S.L. as often as deemed necessary, in order to ensure that it remains aligned at all times with the applicable provisions on personal data protection.