The Management / Governing Body of CANOPY CONSUL, S.L. (hereinafter, the “Controller”), assumes the utmost responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, ensuring the Controller’s continuous improvement with the aim of achieving excellence in relation to compliance with Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (Data Protection Directive) (OJEU L 119/1, 05-04-2016) and the Spanish regulations on the protection of personal data (Organic Law, sector-specific legislation and their implementing regulations).
The Data Protection Policy of CANOPY CONSUL, S.L. rests on the principle of proactive responsibility, according to which the Controller is responsible for compliance with the regulatory framework and case law governing this Policy, and is able to demonstrate it to the competent supervisory authorities.
In this regard, the Controller will be governed by the following principles, which should serve as a guide and framework of reference for all their staff in the processing of personal data:
- Data protection by design: the Controller shall, both when determining the means of processing and at the time of the processing itself, implement appropriate technical and organizational measures, such as pseudonymization, which are designed to implement data protection principles, such as data minimization and to integrate the necessary safeguards into the processing.
- Data protection by default: the Controller shall implement appropriate technical and organizational measures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed.
- Data protection in the information lifecycle: measures ensuring the protection of personal data shall be applicable throughout the entire information lifecycle.
- Lawfulness, fairness and transparency: Personal data shall be processed in a lawful, fair and transparent manner in relation to data subjects.
- Purpose limitation: personal data shall be collected only for specified, explicit and legitimate purposes and shall not be processed further in a way that is not compatible with such purposes.
- Data minimization: personal data must 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 so that personal data that are inaccurate—considering the purposes for their processing—must be deleted or rectified without any delay.
- Storage limitation: personal data must be kept in a form that makes it possible to identify data subjects for no longer than is necessary for the purposes of the processing.
- Integrity and confidentiality: personal data shall be processed in such a way that appropriate security of personal data is ensured. This should include protection against unauthorized or unlawful processing, loss, destruction and damage by taking appropriate technical or organizational measures.
- Information and training: one of the keys for ensuring the protection of personal data is training and information provided to staff involved in their processing. During the information lifecycle, all staff with access to the data shall be properly trained and informed about their obligations in relation to compliance with data protection regulations.
The Data Protection Policy of CANOPY CONSUL, S.L. has been notified to all of the Controller’s staff and is available to all interested parties.
As a result, this Data Protection Policy involves all of the Controller’s staff, who must be aware of and follow it, considering it as their own, with each member being responsible for implementing and verifying the data protection rules applicable to their activity, as well as identifying and providing opportunities for improvement that they consider appropriate in order to achieve excellence in relation to compliance with it.
This Policy shall be revised by the Management / Governing Body of CANOPY CONSUL, S.L., as many times as deemed necessary, to adapt to the current provisions on personal data protection at all times.