Data protection commitment
The Data Protection Policy of GENIUS for PEOPLE, S.L. 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 this Policy and is able to demonstrate such compliance to the competent supervisory authorities.
Fundamental principles
The Data Controller is governed by the following principles as a guide and reference framework for all staff processing personal data: Privacy by design — technical and organisational measures, such as pseudonymisation, are implemented from the moment processing is designed to effectively apply data protection principles like data minimisation. Privacy by default — only the personal data necessary for each specific purpose are processed by default. Protection throughout the information lifecycle — safeguards apply across the entire lifecycle of the information. Lawfulness, fairness and transparency — data is processed lawfully, fairly and transparently. Purpose limitation — data is collected for specified, explicit and legitimate purposes only. Data minimisation — data is adequate, relevant and limited to what is necessary. Accuracy — data is kept accurate and up to date, with inaccurate data erased or rectified without delay. Storage limitation — data is kept only as long as necessary for the purposes it was collected for. Integrity and confidentiality — appropriate security measures protect against unauthorized processing, loss or damage. Information and training — all staff with access to personal data are appropriately trained on their data protection obligations.
Communication and responsibility
This Data Protection Policy is communicated to all staff of the Data Controller and made available to all interested parties. It involves all staff, who must know and adopt it as their own, being individually responsible for applying it and for identifying any improvement opportunities. This Policy is reviewed by the Management/Governing Body of GENIUS for PEOPLE, S.L. as often as necessary to remain aligned with applicable data protection regulations.