The Management / Governing Body of Sapphire Hosteleros S.L (hereinafter, the data controller) assumes the utmost responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, guaranteeing the continuous improvement of the data controller with the aim of achieving 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 natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), and with Spanish legislation on the protection of personal data (Organic Law, specific sectoral legislation and implementing regulations).
The Data Protection Policy of Sapphire Hosteleros S.L is based on the principle of proactive accountability, according to which the data controller is responsible for compliance with the regulatory and case-law framework governing said Policy, and is able to demonstrate such compliance to the competent supervisory authorities.
Accordingly, the data controller shall be governed by the following principles, which must serve as a guide and reference framework for all its staff in the processing of personal data:
- Data protection by design: the data controller shall, both at the time of determining the means of processing and at the time of the processing itself, implement appropriate technical and organisational measures, such as pseudonymisation, designed to effectively apply data protection principles, such as data minimisation, and to integrate the necessary safeguards into the processing.
- Data protection by default: the data controller shall implement appropriate technical and organisational measures to ensure that, by default, only personal data necessary for each specific purpose of the processing are processed.
- Data protection throughout the information life cycle: the measures that guarantee the protection of personal data shall apply throughout the entire information life cycle.
- Lawfulness, fairness and transparency: personal data shall be processed lawfully, fairly and transparently 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 measures shall be taken to ensure that personal data which are inaccurate in relation to the purposes for which they are processed are erased or rectified without delay.
- Storage limitation: personal data shall be kept in a form that permits 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 as to ensure appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, through the application of appropriate technical or organisational measures.
- Information and training: one of the keys to ensuring the protection of personal data is the training and information provided to staff involved in their processing. Throughout the information life cycle, all staff with access to the data shall be appropriately trained and informed of their obligations regarding compliance with data protection regulations.
The Data Protection Policy of Sapphire Hosteleros S.L 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 and assume it as their own. Each member is responsible for applying it and verifying the data protection rules applicable to their activity, as well as identifying and contributing the improvement opportunities they consider appropriate in order to achieve excellence in relation to compliance.
This Policy shall be reviewed by the Management / Governing Body of Sapphire Hosteleros S.L as often as deemed necessary, in order to remain aligned at all times with the current provisions on the protection of personal data.