The Management / Governing Body of SONIA AZA APARICIO (hereinafter, the data controller) assumes full 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 compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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 Spanish regulations on the protection of personal data (Organic Law, specific sectoral legislation, and its implementing regulations).
The Data Protection Policy of SONIA AZA APARICIO is based on the principle of proactive responsibility, according to which the data controller is responsible for complying with the regulatory and jurisprudential framework governing said Policy, and is able to demonstrate this to the competent supervisory authorities.
In this regard, the data controller shall be governed by the following principles, which shall serve as a guide and reference framework for all its staff in the processing of personal data:
- Data protection by design: the controller shall implement appropriate technical and organizational measures, such as pseudonymization, at the time of determining the means of processing and at the time of the processing itself, designed to effectively apply data protection principles, such as data minimization, and to integrate the 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 that are necessary for each specific purpose of the processing are processed.
- Data protection throughout the information lifecycle: measures to ensure the protection of personal data shall apply throughout the entire information lifecycle.
- Lawfulness, fairness, and transparency: personal data will be processed lawfully, fairly, and transparently in relation to the data subject.
- Purpose limitation: personal data shall be collected for specified, explicit, and legitimate purposes and shall not be further processed in a manner that is incompatible with those purposes.
- Data minimization: personal data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
- 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, having regard to the purposes for which they are processed, are erased or rectified without delay.
- Limitation of storage period: personal data will be kept in a form that allows the identification of data subjects for no longer than is necessary for the purposes of processing personal data.
- Integrity and confidentiality: personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using 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 staff involved in processing it. Throughout the information lifecycle, all staff 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 of SONIA AZA APARICIO is communicated to all personnel responsible for data processing and made available to all interested parties.
Consequently, this Data Protection Policy involves all personnel responsible for data processing, who must be familiar with it and accept it as their own, with each member being responsible for applying it and verifying the data protection regulations applicable to their activity, as well as identifying and contributing any opportunities for improvement they deem appropriate with the aim of achieving excellence in compliance.
This Policy will be reviewed by the Management/Governing Body of SONIA AZA APARICIO as often as deemed necessary to ensure that it complies at all times with current regulations on personal data protection.