MANUAL OF POLICIES AND PROCEDURES FOR THE PROCESSING OF PERSONAL DATA
AREA OF APPLICATION
This document applies to the processing of personal data collected by DAVILA P & M. Depending on its nature and purpose, DAVILA P & M SAS may hold the status of responsible for the processing and / or responsible for the processing of personal data that make up the respective database.
DAVILA P & M is domiciled in the city of Barranquilla (Colombia),
Calle 84 # 53 – 46 Floor 2 of. 4
Tel: (5) 378 05 55
The purpose of this document is to regulate the policies and procedures for the Treatment to which the personal data that make up the Databases in respect of which DAVILA P & M SAS acts as Responsible and / or Responsible, as well as the rights of the Holders of the personal data, the commitments acquired by DAVILA P & M SAS with the Data Holders, in their capacity as Responsible or Manager of the Treatment and the procedure adopted so that the Holders can exercise their rights adequately.
For those situations not regulated by this Manual, the provisions of laws 1581 of 2012 and 1266 of 2008 and regulatory decrees 1377 of 2013 and 1727 of 2009 and DU 1074 of 2015 and other complementary regulations will apply.
For interpretative purposes of the rules contained in this document, the following definitions are adopted:
Authorization: Prior, express and informed consent, issued by the owner, for the purpose of submitting your data to a treatment activity.
Database: It is the organized set of personal data subjected to treatment.
Personal data: Any information linked or that may be associated to one or several natural persons, determined or determinable, that make up the Databases.
Private data: The data that due to its intimate or reserved nature is only relevant for the owner.
Public data: It is the data that is not semi-private, private or sensitive. They are considered public data, among others, the data relative to the civil status of the people, to their profession or trade and to their quality of merchant or public servant. By its nature, public data may be contained, among others, in public records, public documents, gazettes and official bulletins and judicial sentences duly executed that are not subject to reservation.
Semiprivate data: The data that does not have an intimate, reserved or public nature and whose knowledge or disclosure may be of interest not only to its owner but to a certain sector or group of people.
Sensitive data: Those that affect the owner’s personal privacy, or whose improper use could generate their discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in unions, social organizations, of human rights or that promotes the interests of any political party or that guarantees the rights and guarantees of opposition political parties, as well as data related to health, sexual life, and biometric data.
Biometric data: All those data related to the physical, physiological or behavioral characteristics of a person that facilitate their identification. Responsible for the treatment: Natural or legal person who, by itself or in association with others, performs the processing of personal data on behalf of the Treatment Manager.
Responsible for the treatment: Natural or legal person, public or private, that by itself or in association with others, decides on the database and / or the treatment of the data.
Data subject: Natural person whose personal data is subject to processing.
Transfer: The transfer of data takes place when the person in charge and / or in charge of the processing of personal data, located in Colombia, sends the information or personal data to a receiver, who in turn is responsible for the treatment and is inside or outside from the country.
Transmission: Processing of personal data that implies the communication of the same inside or outside the territory of the Republic of Colombia when it has for its object the realization of a Treatment by the Manager on behalf of the person in charge.
Treatment: Any operation or set of operations on personal data that DAVILA P & M SAS executes on the personal data that make up the Databases, such as collection, storage, use, circulation or suppression.
Provider: Any natural or legal person that provides goods and / or services to DAVILA P & M SAS by virtue of a contractual relationship.
Client: Any individual or legal entity that acquires goods and / or services marketed or provided by DAVILA P & M SAS.
5 PRINCIPLES FOR THE PROCESSING OF PERSONAL DATA
For the adequate treatment of personal data that make up the Databases as well as in relation to the interpretation and execution of these policies, the following principles will be followed in a harmonic and integral manner:
5.1 PRINCIPLE OF LEGALITY
During all stages and activities of information processing by DAVILA P & M SAS as the person in charge and / or the person in charge or who is designated as the person in charge of processing, application will be made in addition to what is established in this policy, to the standards described. in section 3 and all those that regulate, add, modify or delete.
5.2 PRINCIPLE OF PURPOSE
The Treatment of Personal Data collected by DAVILA P & M SAS will have as its object a legitimate, specific and informed purpose in accordance with the Political Constitution and the Law, which will be communicated to the Owner.
5.3 PRINCIPLE OF FREEDOM
The Treatment shall only be exercised with the prior, express and informed consent of the Holder. DAVILA P & M SAS will not obtain or disclose personal data without prior authorization, or in the absence of legal or judicial mandate that relieves the consent.
5.4 PRINCIPLE OF TRUTHFULNESS OR QUALITY
DAVILA P & M SAS is committed to the owners of the information that makes up its databases, to ensure that it is true, complete, accurate, updated, verifiable and understandable, consequently, it will refrain from dealing with partial, incomplete, fractioned or lead to error.
5.5 PRINCIPLE OF TRANSPARENCY
DAVILA P & M SAS guarantees the right of the Owner to obtain from DAVILA P & M at any time and without restrictions, information about the existence of data concerning him.
5.6 PRINCIPLE OF RESTRICTED ACCESS AND CIRCULATION
The access to the information that makes up the Database is restricted to specialized and previously trained personnel for the manipulation of this type of information. DAVILA P & M SAS does not publish the personal information subject to treatment on the Internet or other means of dissemination or mass communication, unless the access is technically controllable to provide restricted knowledge only to the Holders or authorized third parties in accordance with the law.
5.7 PRINCIPLE OF SECURITY
DAVILA P & M SAS has adopted technical, human and administrative measures, according to the nature of the data under treatment, to grant security to the records and prevent them from being adulterated, lost, consulted, used or accessed by unauthorized personnel or by fraudulent means.
5.8 PRINCIPLE OF CONFIDENTIALITY
Your access to this Site and its use is subject to the legislation and regulations applicable to the matter, as well as the terms and conditions set forth in this document. By accessing and reviewing this Website you agree to these Terms and Conditions, without limitation or conditioning, and acknowledge that they replace and render void any agreement regarding the use of this existing Site between you and DAVILA P & M SAS.
TREATMENT OF PERSONAL DATA
DAVILA P & M, acting as Person in Charge and / or Responsible for the Processing of Personal Data, for the proper development of its corporate purpose and the strengthening of its relationships with third parties, collects, stores, uses, circulates and suppresses Personal Data corresponding to natural persons with whom you have or have had a relationship, such as, without the enumeration meaning limitation, workers and their relatives, suppliers and customers.
By way of example and without prejudice to the fact that in the course of its activity, DAVILA P & M SAS may compile and set up Databases other than those mentioned below, the Personal Data is subject to Treatment by DAVILA P & M SAS with all or some of the the following purposes:
7.1 DATABASES USED
DAVILA P & M SAS collects personal data from potential candidates and their own employees and their family members and / or candidates and workers and their family members of third parties when acting as the person in charge of processing said data, which facilitate, among others, the selection and contracting processes and promotion and execution of certain obligations of a contractual nature, with the following purposes:
a) Establishment of communication channels with the holders of personal data.
b) Realization of selection processes, promotion, labor welfare, payroll, performance and skills, induction, training, training, safety and health in the workplace and environment.
c) Compliance with obligations derived from current labor contracts, directly or through third parties.
d) Fulfillment of obligations related to the execution of the corporate purpose of DAVILA P & M SAS or of the person in charge of the database, when DAVILA P & M SAS acts with respect to this as Manager, inside and outside the national territory.