Commitment to personal data protection


The Management/Governing Body of JAIME ANDRÉS OSPINA FLÓREZ (hereinafter, the data handler), assumes the utmost responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, ensuring the continuous improvement of the data handler 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, in relation to the protection of natural persons with regard to the processing of personal data and free movement of such data and repealing Directive 95/46/CE (General Data Protection Regulation) (OJEU L 119/1, 4-05-2016), and Spanish personal data protection regulations (Organic Law, specific sectoral legislation and its development).

The Data Protection Policy of JAIME ANDRÉS OSPINA FLÓREZ is based on the principle of proactive responsibility, according to which the data handler is responsible for compliance with the regulatory and jurisprudential framework that governs said Policy and is capable of demonstrating this to the competent control authorities.

In this regard, the data handler shall be governed by the following principles which should serve as a guide and frame of reference for all his/her personnel in the processing of personal data:

  1. Data protection by design: the data handler shall implement, both at the time of the determination of the means of processing and at the time of the processing itself, appropriate technical and organisational measures, such as pseudonymisation, designed to effectively implement data protection principles, such as data minimisation, and to integrate the necessary safeguards into the processing.
  1. Data protection by default: the data handler shall implement appropriate technical and organisational measures with a view to ensuring that, by default, only personal data which are necessary for each of the specific purposes of the processing are processed.
  1. Data protection in the lifecycle of the information: measures ensuring the protection of personal data shall apply throughout the entire lifecycle of the information.
  1. Lawfulness, fairness, and transparency: personal data shall be processed lawfully, fairly and transparently in relation to the data subject.
  1. Limitation of purpose: personal data will be collected for specified, explicit and legitimate purposes and will not be further processed in a way incompatible with those purposes.
  1. Minimisation of data: personal data shall be adequate, relevant, and limited to what is necessary for the purposes for which they are processed.
  1. Accuracy: personal data shall be accurate and, where 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 erased or rectified without delay.
  1. Limitation of the retention period: personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
  1. 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, by implementing appropriate technical or organisational measures.
  1. Information and training: one of the keys to guaranteeing the protection of personal data is the training and information provided to personnel involved in data processing. During the life cycle of the information, all personnel with access to the data shall be properly trained and informed about their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of JAIME ANDRÉS OSPINA FLÓREZ is communicated to all personnel of the data handler and made available to all parties concerned.

Consequently, this Data Protection Policy involves all the personnel of the data handler, who must understand and accept it, considering it as their own, with each member being responsible for applying it and verifying the data protection regulations 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 compliance with it.

This Policy shall be reviewed by the Management/Governing Body of JAIME ANDRÉS OSPINA FLÓREZ, as many times as deemed necessary, in order to adapt, at all times, to the provisions in force regarding the protection of personal data.