OUR COMMITMENT TO PERSONAL DATA PROTECTION: “INFORMED PEOPLE AND PROTECTED DATA”
The Management / Governing Body of Luigi Donatelli (hereinafter referred to as the data controller) assumes full responsibility and commitment to the establishment, implementation, and maintenance of this Data Protection Policy, ensuring the continuous improvement of the data controller to achieve 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 the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), and the Spanish personal data protection regulations (Organic Law, specific sectoral legislation, and its implementing rules).
The Data Protection Policy of Luigi Donatelli is based on the principle of proactive responsibility, whereby the data controller is accountable for compliance with the regulatory and jurisprudential framework governing this Policy and can demonstrate this compliance to the competent supervisory authorities.
In this regard, the data controller will adhere to the following principles, which must serve as a guide and reference framework for all its personnel when processing personal data:
Data Protection by Design: The data controller will implement appropriate technical and organizational measures, such as pseudonymization, both when determining the means of processing and during the processing itself. These measures will be designed to effectively apply data protection principles, such as data minimization, and to integrate necessary safeguards into the processing.
Data Protection by Default: The data controller will apply appropriate technical and organizational measures to ensure that, by default, only personal data necessary for each specific purpose of processing is processed.
Data Protection throughout the Information Lifecycle: Measures ensuring the protection of personal data will be applicable throughout the entire lifecycle of the information.
Lawfulness, Fairness, and Transparency: Personal data will be processed lawfully, fairly, and transparently concerning the data subject.
Purpose Limitation: Personal data will be collected for specific, explicit, and legitimate purposes and will not be processed further in a manner incompatible with those purposes.
Data Minimization: Personal data will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
Accuracy: Personal data will be accurate and, where necessary, kept up to date. Reasonable steps will be taken to ensure that inaccurate personal data concerning the purposes for which they are processed are erased or rectified without delay.
Storage Limitation: Personal data will be kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed.
Integrity and Confidentiality: Personal data will be processed in a manner that ensures appropriate security of the data, 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 keys to ensuring personal data protection is the training and information provided to staff involved in processing such data. Throughout the information lifecycle, all staff with access to data will be properly trained and informed of their obligations concerning compliance with data protection regulations.
The Data Protection Policy of Luigi Donatelli is communicated to all personnel of the data controller and made available to all interested parties.
As a result, this Data Protection Policy involves all personnel of the data controller, who must know and embrace it as their own. Each member is responsible for applying it and verifying the data protection rules applicable to their activities, as well as identifying and suggesting any improvement opportunities they consider appropriate to achieve excellence in compliance.
This Policy will be reviewed by the Management / Governing Body of Luigi Donatelli as often as deemed necessary to adapt it at all times to the provisions in force concerning personal data protection.
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