Data Protection Commitment
The Management/Governing Body of GENIUS for PEOPLE, S.L. (hereinafter, the Data Controller) assumes the highest responsibility and commitment to the establishment, implementation, and maintenance of this Data Protection Policy, ensuring the continuous improvement of the Data Controller with the objective 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, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), as well as the Spanish regulations on personal data protection (Organic Law, specific sectoral legislation, and its implementing regulations).
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
In this regard, the Data Controller shall be governed by the following principles, which must serve all its staff as a guide and reference framework in the processing of personal data:
Privacy by Design
The Data Controller shall implement, both at the time of determining the means of processing and during the processing itself, appropriate technical and organisational measures—such as pseudonymisation—designed to effectively apply data protection principles, such as data minimisation, and integrate the necessary safeguards into the processing.
Privacy by Default
The Data Controller shall apply appropriate technical and organisational measures to ensure that, by default, only personal data necessary for each specific purpose of processing are processed.
Protection Throughout the Information Lifecycle
Measures ensuring the protection of personal data shall be applicable throughout the entire lifecycle 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 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; all reasonable steps shall be taken to ensure that inaccurate personal data are erased or rectified without delay, having regard to the purposes for which they are processed.
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 unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.
Information and Training
One of the key elements in ensuring the protection of personal data is the training and information provided to staff involved in processing such data. Throughout the information lifecycle, all personnel with access to the data shall be appropriately trained and informed about their obligations regarding compliance with data protection regulations.
Communication and Responsibility
The Data Protection Policy of GENIUS for PEOPLE, S.L. is communicated to all staff of the Data Controller and made available to all interested parties.
As a result, this Data Protection Policy involves all staff of the Data Controller, who must know and adopt it as their own, being individually responsible for applying it and verifying the data protection rules applicable to their activity, as well as identifying and contributing any improvement opportunities they deem appropriate to achieve excellence in compliance.
This Policy shall be reviewed by the Management/Governing Body of GENIUS for PEOPLE, S.L. as often as deemed necessary, in order to remain at all times in line with the provisions in force regarding the protection of personal data.If you want, I can now merge this policy with the Legal Notice you shared before so your website legal section is perfectly structured, harmonized, and bilingual in one clean document—something very useful for GDPR compliance and international clients.
