Data protection policy

The Management / Governing Body of DS REFINISH SLU (hereinafter, the data controller), assumes the maximum responsibility and commitment with the establishment, implementation and maintenance of this Data Protection Policy, guaranteeing the continuous improvement of the data controller in order to achieve excellence in relation to compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 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 (General Data Protection Regulation) (OJEU L 119/1, 04-05-2016) and the Spanish legislation on the protection of personal data (Organic Law, specific sectoral legislation and its implementing provisions).

The Data Protection Policy of DS REFINISH SLU is based on the principle of proactive liability, according to which the data controller is responsible for compliance with the regulatory and jurisprudential framework governing the Policy, and is able to demonstrate this to the competent supervisory authorities.

In this regard, the data controller shall be governed by the following principles which shall serve as a guide and reference framework for its entire staff in the processing of personal data:

  • Data protection from the design stage: The data controller shall apply appropriate technical and organisational measures, such as pseudonymisation, designed to effectively apply data protection principles, such as data minimisation, both when determining the means of processing at the time of processing, and to integrate the necessary safeguards into the processing.
  • Data protection by default: The data controller shall apply appropriate technical and organisational measures to ensure that, by default, only personal data that are necessary for each of the specific purposes of the processing are processed.
  • Data protection in the information life cycle: Measures to ensure the protection of personal data shall apply throughout the entire life cycle of the information.
  • Legality, fairness and transparency: Personal data shall be processed in a lawful, fair and 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, if necessary, kept up to date; all reasonable steps shall be taken to ensure that personal data which are inaccurate in relation to the purposes for which they are processed are deleted or rectified without delay.
  • Limitation of the storage period: Personal data shall be kept in such a way as to enable the identification of data subjects for no longer than is necessary for the purposes of the processing of personal data.
  • Integrity and confidentiality: Personal data shall be processed in such a way so as to ensure adequate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by the application of appropriate technical or organisational measures.
  • Information and training: One of the keys to guaranteeing the protection of personal data is the training and information provided to the staff involved in their processing. During the life cycle of the information, 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 DS REFINISH SLU is communicated to the entire data controller’s staff and made available to all interested parties.

Consequently, this Data Protection Policy involves all the data controller’s staff, who must know and accept it, considering it as their own, and each member is responsible for applying it and verifying the data protection rules applicable to their activity, as well as identifying and providing the opportunities for improvement that they consider appropriate with the aim of achieving excellence in relation to its compliance.

This Policy will be reviewed by the Management / Governing Body of DS REFINISH SLU, as many times as it deems necessary, to adapt it, at all times, to the current provisions on the protection of personal data.