The Management Body of SIGNATURE MANAGEMENT CONSULTANTS, S.L.U. (hereinafter, the data controller) assumes the utmost responsibility for 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, GDPR) (OJEU L 119/1, 04-05-2016), and with Spanish personal data protection legislation (Spanish Organic Law, specific sectoral legislation and their implementing rules).
The Data Protection Policy of SIGNATURE MANAGEMENT CONSULTANTS, S.L.U. rests on the principle of proactive accountability, according to which the data controller is responsible for compliance with the regulatory and case-law framework governing that 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 must serve all of its personnel as a guide and frame of reference in the processing of personal data:
Data protection by design: the data controller shall implement, both at the time of determining the means of processing and at the time of the processing itself, appropriate technical and organisational measures, such as pseudonymisation, designed to implement data protection principles, such as data minimisation, in an effective manner and to integrate the necessary safeguards into the processing.
Data protection by default: the data controller shall implement appropriate technical and organisational measures with a view to ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed.
Data protection throughout the information life cycle: the measures ensuring the protection of personal data shall be applicable throughout the entire life cycle 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 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 minimisation: 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.
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 of the processing of the personal data.
Integrity and confidentiality: personal data shall be processed in such a manner as to ensure appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, through the implementation of appropriate technical or organisational 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 life cycle of the information, all personnel with access to the data shall be duly trained and informed about their obligations in relation to compliance with data protection legislation.
The Data Protection Policy of SIGNATURE MANAGEMENT CONSULTANTS, S.L.U. is communicated to all of the data controller's personnel and made available to all interested parties.
Consequently, this Data Protection Policy involves all of the data controller's personnel, who must be familiar with it and embrace it, regarding it as their own, each member being responsible for applying it and for verifying the data protection rules applicable to their activity, as well as for identifying and putting forward any improvement opportunities they consider appropriate with the aim of achieving excellence in relation to compliance with it.
This Policy shall be reviewed by the Management Body of SIGNATURE MANAGEMENT CONSULTANTS, S.L.U. as often as deemed necessary, so that it is adapted at all times to the provisions in force on the protection of personal data.