The Governing Body/Management of REPRESENTACIONES STEEL-MET SL (hereinafter, the data controller) takes on the maximum responsibility and commitment to establish, implement and maintain this Data Protection Policy, guaranteeing 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, regarding the protection of natural persons with regard to processing personal data and the free circulation of said data and which repeals Directive 95/46/EC (General Data Protection Regulation) (DOUE L 119/1, 04-05-2016), and Spanish regulations on the protection of personal data (Organic Law, sector-specific legislation and its implementing regulations).
The Data Protection Policy of REPRESENTACIONES STEEL-MET SL is based on the principle of proactive responsibility, according to which the controller is responsible for complying with the regulatory and jurisprudential framework that governs said Policy, and is able to demonstrate so to the competent control authorities.
In this sense, the data controller shall operate according to the following principles that should help all members of staff as a guide and reference framework when processing personal data:
Data protection by design: the controller will apply, both when establishing the means of processing and at the time of processing, the appropriate technical and organisational measures, such as pseudonymisation, created to effectively apply the principles of data protection, such as data minimisation, and implementing the necessary guarantees for processing data.
Data protection by default: the controller will apply the appropriate technical and organisational measures in order to guarantee that, by default, only the personal data that are necessary for each of the specific purposes of processing is subject to processing.
Data protection and the information life cycle: the measures that guarantee the protection of personal data will be applicable during the complete life cycle of the information.
Lawfulness, loyalty and transparency: personal data will be processed in a lawful, loyal and transparent manner in relation to the interested party.
Purpose limitation: personal data will be collected for specific, explicit and legitimate purposes, and will not be processed further in a manner that is incompatible with said purposes.
Data minimisation: 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, if necessary, updated. All reasonable measures will be taken so that inaccurate personal data with respect to the purposes for which they are processed are deleted or rectified without delay.
Storage limitation: personal data will be stored in such a way that identifying interested parties is allowed for no longer than necessary for the purposes of processing personal data.
Integrity and confidentiality: personal data will be processed in such a way as to guarantee the adequate safety of personal data, including protection against unauthorised or unlawful processing and against losing, destroying or accidentally damaging said data, by applying the appropriate technical or organisational measures.
Information and training: one of the key elements to guaranteeing personal data protection is training and providing information to the members of staff involved in processing said data. During the information life cycle, all members of staff with access to personal data will be trained and informed about their obligations in relation to complying with data protection regulations.
The Data Protection Policy of REPRESENTACIONES STEEL-MET SL is explained to all members of staff of the data controller and made available to all interested parties.
As a result, this Data Protection Policy involves all the members of staff responsible for processing data who must understand and accept it, considering it as their own. Each member of staff will be responsible for applying it and verifying the data protection regulations applicable to their activity, as well as identifying and providing opportunities for improvement that are deemed appropriate with the aim of achieving excellence in relation to compliance.
This Policy will be reviewed by the Governing Body/Management of REPRESENTACIONES STEEL-MET SL as many times as deemed necessary in order to comply at all times with the provisions in force regarding protecting personal data.