The Management / Governing Body of ABOGALEX ABOGADOS, S.L.P. (hereinafter, the Data Controller), assumes the maximum 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) (OJEU L 119/1, 04-05-2016), and Spanish personal data protection regulations (Organic Law, specific sectoral legislation and its implementing rules).
The Data Protection Policy of ABOGALEX ABOGADOS, S.L.P. rests on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the regulatory and jurisprudential framework governing said Policy, and is able to demonstrate it to the competent control authorities.
In this regard, the controller shall 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:
1. Data protection by design: the controller shall implement, both at the time of determining the means of processing and at the time of the processing itself, appropriate technical and organizational measures, such as pseudonymization, designed to effectively implement data protection principles, such as data minimization, and to integrate the necessary safeguards into the processing.
2. Data protection by default:the controller shall implement appropriate technical and organizational measures with a view to ensuring that, by default, only personal data that are necessary for each of the specific purposes of the processing are processed.
3. Data protection in the life cycle of the information: the measures that guarantee the protection of personal data shall be applicable during the entire life cycle of the information.
4. Lawfulness, fairness and transparency:the personal data will be processed in a lawful, fair and transparent manner in relation to the data subject.
5. Purpose limitation: personal data will be collected for specified, explicit and legitimate purposes and will not be further processed in a way incompatible with those purposes.
6. Data minimization: personal data will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
7. Accuracy: the personal data shall be accurate and, if necessary, kept up to date; all reasonable steps shall 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.
8. Limitation of the retention period: the personal data will be kept in a form that allows the identification of the data subjects for no longer than is necessary for the purposes of the processing of the personal data.
9. Integrity and confidentiality: the personal data will be processed in such a way as to ensure adequate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, through the implementation of appropriate technical or organizational measures.
10. Information and training: one of the keys to guarantee the protection of personal data is the training and information provided to the personnel involved in the processing of such data. During the life cycle of the information, all personnel with access to the data will be properly trained and informed about their obligations in relation to compliance with data protection regulations.
The Data Protection Policy of ABOGALEX ABOGADOS, S.L.P. is communicated to all staff of the data controller and made available to all interested parties.
Consequently, this Data Protection Policy involves all the staff of the data controller, who must know it and assume it, considering it as their own, each member being responsible for applying it and verifying the data protection rules applicable to their activity, as well as identifying and providing the opportunities for improvement that they consider appropriate in order to achieve excellence in relation to their compliance.
This Policy will be reviewed by the Management / Governing Body of ABOGALEX ABOGADOS, S.L.P., as many times as deemed necessary, in order to adapt, at all times, to the provisions in force regarding the protection of personal data.