Information Protection of personal data

Data Controller

The companies of the CLIKALIA Group identified in Point 1 of the Legal Notice.

Data category

·          Name and surname, telephone, and e-mail (if the whistleblowing is not anonymous).

·          Facts related to the complaints and other information provided by the informant such as name and surname of the complainant and witnesses, personal characteristics, employment details, signature, etc.

·          Infractions and administrative sanctions.

·          No data of special categories will be processed, except that can be provided by the informant.

Purpose of the Process

Reception and management of communications and queries received through the ethical channel, as well as the instruction and investigation of files related to infractions for the detection of crimes and prevention of criminal responsibilities, avoid conduct contrary to internal regulations, as well as any other that is applicable.

Legitimation

·          The process is based on the public interest in accordance with the article 6.1.e) RGPD in relation to The LOPDgdd.

·          Legitimate interest of the company to conduct the necessary checks to detect and prevent breaches or breaches of our internal regulations (art. 6.1 f RGPD).

Data retention

Personal data will be kept in accordance with the provisions of law. Specifically, the data will be kept for the time necessary to decide on the appropriateness of initiating an investigation into the facts communicated, which may last for a maximum of three (3) months from since the date of registration of the communication/complaint.

In any case, after this time, all that data must be deleted from the system, unless the purpose of conservation is to leave evidence of the operation of the channel, in which case they will be anonymized.

However, in case it is necessary to process the personal data for a longer time to continue the investigation or because it is decided to take legal action, the data will be kept, in an environment other than the ethical channel, as long as it is necessary to conclude the investigation or for the exercise of actions by Clikalia in the corresponding legal proceedings.

Communications/complaints that have not been acted upon will only be recorded in the system in anonymized form but will not be blocked.

Recipients

Likewise, ethical channel data will be communicated to external professional cloud hosting service providers and ethical channel management providers who will process the data as Data Processors and, when necessary, to HR personnel for the adoption of possible sanctions or disciplinary measures.

The facts that may constitute a criminal or administrative offence, including personal data, may be communicated to the Security Forces and Corps, the Public Prosecutor's Office, the Judiciary or other public administrations with competence in relation to the type of communication submitted.

International data transfers

No international transfers will be made for the purpose of this processing, except to competent authorities outside the national territory on the basis of public interest or the fulfillment of legal obligations for the formulation, exercise or defense of claims.

Rights

The interested party may exercise their rights of access, rectification, deletion and portability data, limitation, and opposition, as well as not being subject to decisions based solely on the automated processing of their data, when appropriate, at the addresses identified above.

Likewise, we inform you that you can make a claim before the Spanish Agency for Data Protection, in case you consider that the processing of your data is not adequate ( www.aepd.es )