Data Controller
GLOBAL MANAGER SPAIN, SL
Tax Identification Number (NIF): B47641402
Registered office: Paseo Pérez de Ayala, 9, Unit 10 – 47008 – Valladolid
Telephone: 901 727 727
Email: legal@gmiberia.com
A. Project Candidates
| Purpose |
To carry out staff recruitment processes. |
| Legal basis |
Performance of a contract (GDPR Art. 6(1)(b)). |
| Retention |
Two years from the last interaction. |
| Recipients |
Data is not disclosed to third parties unless required by law. |
| Rights |
Access, rectification, erasure, data portability and objection. To exercise these rights: legal@gmiberia.com |
| Source |
The data subject themselves. |
B. Candidates in the Managers’ Database
| Purpose |
To manage the managers’ database, assess applications, communicate future opportunities and projects, and transfer data to client companies seeking interim managers. |
| Legal basis |
Consent of the data subject (GDPR Art. 6(1)(a)). |
| Retention |
Until a request for erasure is made. |
| Recipients |
Client companies seeking interim managers (as required by contract). |
| Rights |
Access, rectification, erasure, data portability and objection. |
| Source |
The data subject themselves. |
C. Clients
| Purpose |
Provision of services, administrative, accounting and tax management, and sending of promotional communications. |
| Legal basis |
Performance of a contract (GDPR Art. 6(1)(b)); legitimate interest (Recital 47 GDPR; LSSICE Art. 21(2)). |
| Retention |
Until a request for erasure is made; additional periods where required by law. |
| Recipients |
Tax authorities (legal obligation); financial institutions (contractual requirement). |
| Rights |
Access, rectification, erasure, data portability and objection. |
| Source |
The data subject themselves. |
D. Potential Customers and Contacts
| Purpose |
To manage enquiries from potential customers and send promotional communications. |
| Legal Basis |
Performance of a contract (GDPR Art. 6(1)(b)); consent (LSSICE Art. 21); legitimate interest (LOPDGDD Art. 19; GDPR Art. 6(1)(f)). |
| Retention |
Until a request for erasure is made. |
| Recipients |
Data is not disclosed to third parties unless required by law. |
| Rights |
Right of access, rectification, erasure, data portability and objection. |
| Source |
The data subject themselves. |
E. Suppliers
| Purpose |
Tax, accounting and administrative management of the contracted services and maintenance of professional contact details. |
| Legal basis |
Performance of a contract (GDPR Art. 6(1)(b)); legitimate interest (LOPDGDD Art. 19; GDPR Art. 6(1)(f)). |
| Retention |
Until deletion is requested; additional periods as required by legal obligations. |
| Recipients |
Tax authorities (legal obligation); financial institutions (contractual requirement). |
| Rights |
Access, rectification, erasure, data portability and objection. |
| Source |
The data subject themselves. |
F. Video surveillance
| Purpose |
To ensure the safety of people, property and premises. |
| Legal basis |
Task carried out in the public interest (GDPR Art. 6(1)(e)). |
| Retention |
Maximum 30 days, unless information is passed on to the State Security Forces. |
| Recipients |
State law enforcement agencies; courts and tribunals in the event of a complaint. |
| Rights |
Right of access, rectification, erasure, data portability and objection. |
| Source |
The data subject themselves. |
G. Staff
| Purpose |
Management of the employment relationship, training, occupational risk prevention and health surveillance, payroll, social security, time recording and management of workplace accidents. |
| Legal basis |
Performance of the employment contract (GDPR Art. 6(1)(b)); compliance with legal obligations (labour regulations, health and safety regulations and social security regulations). |
| Retention |
For the duration of the employment relationship and any additional periods required by applicable legislation. |
| Recipients |
Tax authorities, Social Security and the Mutual Insurance Scheme (legal obligation); banks (payroll processing); Fundae (training subsidy). |
| Rights |
Access, rectification, erasure, data portability and objection. |
| Source |
The data subject themselves. |
H. Exercising Rights
| Purpose |
To process requests relating to the rights set out in data protection legislation. |
| Legal basis |
Compliance with a legal obligation (GDPR Art. 6(1)(c)). |
| Retention |
For the time necessary to resolve the request, plus three years to deal with any potential complaints. |
| Recipients |
Supervisory authorities, relevant public administration bodies and the Ombudsman. |
| Rights |
Right of access, rectification, erasure, data portability and objection. |
| Source |
The data subject themselves. |
Rights of Data Subjects
Every person has the right to:
- Obtain confirmation as to whether or not personal data concerning them are being processed.
- Access their personal data.
- Request the rectification of inaccurate data.
- Request the erasure of their data where, amongst other reasons, the data is no longer necessary for the purposes for which it was collected.
- Request data portability.
- To request restriction of processing, in which case the data will only be retained for the purpose of exercising or defending legal claims.
- Object to the processing on grounds relating to your particular situation; the data controller will cease processing the data unless there are compelling legitimate grounds or for the establishment, exercise or defence of legal claims.
- Withdraw the consent given at any time, without this affecting the lawfulness of the processing carried out prior to its withdrawal.
Exercising your rights: please write to legal@gmiberia.com
Complaints: the data subject may lodge a complaint with the Spanish Data Protection Agency at www.aepd.es, in particular where they have not received a satisfactory response regarding the exercise of their rights.
Automated decisions: no automated decisions or profiling are carried out in any of the processing operations described.
International data transfers: no international data transfers are envisaged in any of the above categories.
