The Management of CAR-TEC Automotive Engineering S.L. (hereinafter, the data controller), assumes the highest responsibility and commitment to the establishment, implementation, and maintenance of this Data Protection Policy, ensuring the continuous improvement of the data controller in order 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 on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), and the applicable Spanish legislation on personal data protection (Organic Law, specific sectoral legislation, and its implementing regulations)..
CAR-TEC Automotive Engineering S.L.'s Data Protection Policy is based on the principle of proactive responsibility, according to which the data controller is accountable for complying with the legal and jurisprudential framework governing this Policy and is able to demonstrate such compliance to the competent supervisory authorities.
In this regard, the data controller shall be guided by the following principles, which must serve all personnel as a reference framework in the processing of personal data:
- Data protection by design: the data controller shall implement appropriate technical and organizational measures—such as pseudonymization—both when determining the means of processing and during the processing itself, to effectively apply data protection principles such as data minimization, and to integrate the necessary safeguards into the processing.
- Data protection by default: the data controller shall implement appropriate technical and organizational measures to ensure that, by default, only personal data necessary for each specific purpose of the processing are processed.
- Data protection throughout the information lifecycle: measures ensuring personal data protection shall apply throughout the entire information lifecycle.
- 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 not further processed in a manner incompatible with those purposes.
- Data minimization: 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; every reasonable step must be taken to ensure that inaccurate personal data are erased or rectified without delay, having regard to the purposes for which they are processed.
- 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 for which the personal data are processed.
- Integrity and confidentiality: personal data shall be processed in a manner that ensures appropriate security, 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 data processing. Throughout the information lifecycle, all personnel with access to the data shall be appropriately trained and informed about their obligations regarding data protection compliance.
CAR-TEC Automotive Engineering S.L.'s Data Protection Policy is communicated to all personnel of the data controller and made available to all interested parties.
Consequently, this Data Protection Policy involves all personnel of the data controller, who must be aware of it and take ownership of it, being individually responsible for applying it, verifying the data protection rules applicable to their activities, and identifying and suggesting opportunities for improvement with the aim of achieving excellence in compliance.
This Policy will be reviewed by the Management / Governing Body of CAR-TEC Automotive Engineering S.L. as often as necessary to ensure it is always aligned with the current regulations on personal data protection.