Personal Data Protection Commitment

Our commitment to personal data protection: “informed people and protected data.”

The Management / Governing Body of FUNDACIÓN COLUMBUS (hereinafter, the data controller) assumes full responsibility and commitment for establishing, implementing, and maintaining this Data Protection Policy, ensuring 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, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016), and with Spanish personal data protection legislation (Organic Law, sector-specific legislation, and implementing regulations).

The Data Protection Policy of FUNDACIÓN COLUMBUS is based on the principle of accountability, under which the data controller is responsible for complying with the regulatory and case-law framework governing this Policy and must be able to demonstrate such compliance to the competent supervisory authorities.

Accordingly, the data controller will be governed by the following principles, which must guide all its staff and serve as a framework for the processing of personal data:

1. Data protection by design: the data controller will implement, both when determining the means of processing and at the time of processing itself, appropriate technical and organizational measures, such as pseudonymization, designed to effectively apply data protection principles, such as data minimization, and to integrate the necessary safeguards into the processing.

2. Data protection by default: the data controller will implement appropriate technical and organizational measures to ensure that, by default, only personal data necessary for each specific purpose of the processing is processed.

3. Data protection throughout the information life cycle: the measures that ensure the protection of personal data will apply throughout the entire life cycle of the information.

4. Lawfulness, fairness, and transparency: personal data will be processed lawfully, fairly, and transparently 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 manner 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 it is processed.

7. Accuracy: personal data will be accurate and, where necessary, kept up to date. Every reasonable step will be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay.

8. 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.

9. Integrity and confidentiality: personal data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.

10. Information and training: one of the keys to ensuring the protection of personal data is the training and information provided to all staff involved in processing it. Throughout the information life cycle, all staff with access to the data will be properly trained and informed of their obligations regarding compliance with data protection regulations.

The Data Protection Policy of FUNDACIÓN COLUMBUS is communicated to all staff of the data controller and made available to all interested parties.

Consequently, this Data Protection Policy involves all staff of the data controller, who must be familiar with it and embrace it as their own. Each member is responsible for applying it and for verifying the data protection rules applicable to their activity, as well as for identifying and suggesting any improvements they consider appropriate in order to achieve excellence in its compliance.

This Policy will be reviewed by the Management / Governing Body of FUNDACIÓN COLUMBUS as often as necessary to keep it aligned at all times with current personal data protection regulations.