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Purpose

Management of personal data related to compliance systems (crime prevention, code of conduct, anti-corruption, conflict of interest, transparency).


Entity in charge


The legal basis for processing is:

  • Article 6(1)(c) of GDPR: Processing is necessary for compliance with a legal obligation to which the controller is subject:
    • Organic Law 10/1995, of November 23, of the Penal Code.
    • Law 3/2015, of March 30, regulating the exercise of high office.
    • Law 19/2013, of December 9, on transparency, access to information, and good governance.

Data retention periods

Data will be stored for the time necessary to comply with the purpose for which they were collected and to determine the possible liabilities that could derive from that purpose and data processing. The provisions of the file and documentation regulations applicable to Navantia will apply.

Organic Law 10/1995, of November 23, of the Penal Code (15 years) will be applied.


Affected groups

Employees; Clients; Suppliers.


Data type - Infringement

  • Administrative infractions and criminal convictions.

Data types - Special categories

Not processed.

Data type - Identification data

  • Name and surname
  • NIF (NIE, Passport or Residence Card Number)
  • Address
  • Telephone
  • Email
  • Image
  • Signature (handwritten or electronic)

Data type - Other

  • Personal characteristics
  • Preferences
  • Academic and professional data
  • Employment details and/or job performance
  • Physical or virtual location data
  • Online identity, web browsing, electronic communication metadata
  • Profile data (social media, economic solvency, psychological)

Security measures

The security measures applied correspond to those provided in Annex II (Security Measures) of Royal Decree 311/2022, of May 3, which regulates the National Security Scheme in the field of Electronic Administration and are described in the documents forming part of Navantia’s Data Protection and Information Security Policy. Security measures corresponding to Annex A of UNE-EN/IEC 27001 - Information Security Management Systems.

Additionally, security measures are adopted for paper-based documentation according to the risks to which they are exposed, in order to ensure the confidentiality of the processed data.


Communication

Communications are foreseen when data can be communicated in accordance with Article 6 of GDPR, in relation to authorised processing of:

  • Courts of Justice

International transfers

Not foreseen.