Data protection

The Management / Governing Body of SOPORTES DE LECTURA SL (hereinafter, the Data Controller) assumes the highest responsibility and commitment to the establishment, implementation, and maintenance of this Data Protection Policy, guaranteeing 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 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, which repeals Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), and with Spanish legislation on the protection of personal data (Organic Law, specific sectoral legislation, and its implementing regulations).

The Data Protection Policy of SOPORTES DE LECTURA SL is based on the principle of proactive responsibility, according to which the Data Controller is responsible for complying with the regulatory and jurisprudential framework that governs this Policy and is able to demonstrate such compliance to the competent supervisory authorities.

Principles

In this regard, the Data Controller shall be guided by the following principles, which must serve as a guide and reference framework for all its personnel in the processing of personal data:

• Data protection by design: The Data Controller shall apply, both when determining the means of processing and during 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.
• Data protection by default: The Data Controller shall apply appropriate technical and organizational measures to ensure that, by default, only the personal data necessary for each specific purpose of the processing are processed.
• Data protection throughout the information lifecycle: Measures that ensure 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 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 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; all reasonable steps shall be taken to ensure that inaccurate personal data 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 for which the personal data are processed.
• Integrity and confidentiality: Personal data shall be processed in a manner that ensures appropriate security, 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 key elements to ensure the protection of personal data is the training and information provided to personnel involved in their processing. Throughout the information life cycle, all staff with access to data shall be properly trained and informed about their obligations regarding data protection compliance.

The Data Protection Policy of SOPORTES DE LECTURA SL is communicated to all personnel of the Data Controller and made available to all interested parties.

Consequently, this Data Protection Policy involves all personnel of the Data Controller, who must know and assume it as their own, being each member responsible for its application and for verifying the data protection regulations applicable to their activity, as well as identifying and proposing improvement opportunities aimed at achieving excellence in compliance.

This Policy shall be reviewed by the Management / Governing Body of SOPORTES DE LECTURA SL as often as deemed necessary to ensure its alignment with the current provisions on the protection of personal data.