Personal data protection commitment

The Management / Governing Body of IDIM GESTIÓN DENTAL SL (hereinafter, the data controller), assumes maximum 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 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, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016), and with Spanish personal data protection regulations (Organic Law, specific sector legislation, and its implementing regulations).

The Data Protection Policy of IDIM GESTIÓN DENTAL SL is based on the principle of proactive responsibility (accountability), according to which the data controller is responsible for compliance with the regulatory and jurisprudential framework governing said Policy, and must be capable of demonstrating it to the competent supervisory authorities.

In this regard, the data controller shall be governed by the following principles, which must serve all its personnel as a guide and framework of reference in the processing of personal data:

1. Data protection by design: both at the time of the determination of the means for processing and at the time of the processing itself, the data controller shall implement appropriate technical and organisational measures, such as pseudonymisation, which are designed to implement data-protection principles, such as data minimisation, in an effective manner and to integrate the necessary safeguards into the processing.
2. Data protection by default: the data controller shall implement appropriate technical and organisational measures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed.
3. Data protection in the information life cycle: measures ensuring the protection of personal data shall be applicable throughout the complete life cycle of the information.

3. Lawfulness, fairness and transparency: personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject.
4. Purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
5. Data minimisation: personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
6. Accuracy: personal data shall be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
7. Storage limitation: 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.
8. Integrity and confidentiality: personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
9. Information and training: one of the keys to guaranteeing personal data protection is the training and information provided to the personnel involved in their processing. Throughout the information life cycle, all personnel with access to data shall be properly trained and informed regarding their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of IDIM GESTIÓN DENTAL SL 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 and accept it, considering 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 any improvement opportunities they deem appropriate with the aim of achieving excellence in relation to its compliance.

This Policy shall be reviewed by the Management / Governing Body of IDIM GESTIÓN DENTAL SL as often as deemed necessary, in order to adapt, at all times, to the current provisions regarding personal data protection.