The Management / Governing Body of HOTEL GRAN LAGUNA, S.L. (hereinafter, the data controller), assumes the highest responsibility and commitment to the establishment, implementation, and maintenance of this data protection policy, ensuring the continuous improvement of the data controller with the aim of achieving excellence in relation to compliance with Regulation (EU) 2016/679 of the European Parliament and the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), as well as Spanish personal data protection regulations (Organic Law, specific sectorial legislation, and its development rules).

The data protection policy of HOTEL GRAN LAGUNA, S.L. is based on the principle of proactive responsibility, according to which the data controller is responsible for complying with the regulatory and jurisprudential framework governing this policy and is able to demonstrate this to the competent supervisory authorities. In this regard, the data controller will be guided by the following principles, which should serve as a guide and framework for all its staff in the processing of personal data:

1. Data protection by design: The data controller will apply, both when determining the means of processing and during the processing itself, appropriate technical and organizational measures, such as pseudonymization, designed to effectively implement data protection principles, such as data minimization, and integrate the necessary safeguards into the processing.
2. Data protection by default: The data controller will apply appropriate technical and organizational measures to ensure that, by default, only the personal data necessary for each specific purpose of the processing is processed.
3. Data protection throughout the information lifecycle: Measures ensuring the protection of personal data will be applicable throughout the entire lifecycle of the information.
4. Lawfulness, fairness, and transparency: Personal data will be processed lawfully, fairly, and in a transparent manner in relation to the data subject.
5. Purpose limitation: Personal data will be collected for specified, legitimate, and explicit purposes, and will not be further processed in a manner incompatible with those purposes.
6. Data minimization: Personal data will be adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
7. Accuracy: Personal data will be accurate and, if necessary, kept up to date; all reasonable measures will be taken to ensure that inaccurate personal data is erased or rectified without delay, in relation to the purposes for which it is processed.
8. Storage limitation: Personal data will be kept in a form which allows the identification of the data subject for no longer than is necessary for the purposes of the processing.
9. Integrity and confidentiality: Personal data will be processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, through the use of appropriate technical or organizational measures.
10. Information and training: One of the keys to ensuring personal data protection is the training and information provided to staff involved in processing the data. Throughout the information lifecycle, all staff with access to the data will be adequately trained and informed about their obligations in relation to compliance with data protection regulations.

The data protection policy of HOTEL GRAN LAGUNA, S.L. is communicated to all staff of the data controller and made available to all interested parties. Consequently, this policy involves all staff of the data controller, who must be aware of it and adopt it, considering it their own, with each member responsible for applying it and verifying data protection standards according to their activity, as well as identifying and suggesting any improvement opportunities they deem appropriate in order to achieve excellence in relation to compliance. This policy will be reviewed by the Management / Governing Body of HOTEL GRAN LAGUNA, S.L. as often as deemed necessary to ensure it is always in line with the current provisions regarding the protection of personal data.

Identification of the data controller

Name and contact details of the data controller:

• Company name: HOTEL GRAN LAGUNA, S.L.
• CIF / NIF: B76707868
• Activity: Hospitaly.
• Contact phone: (+34) 922 24 01 30
• Registered address: C/ Doctor José Naveiras, nº24, 38001, Santa Cruz de Tenerife.
• Address for notifications: C/ Nava y Grimón, nº18, 38201, San Cristóbal de La Laguna (Santa Cruz de Tenerife).
• Contact email: reservas@lalagunagranhotel.com
• Website: lalagunagranhotel.com

Purpose of the document

The Spanish Data Protection Agency, in its Strategic Plan 2015-2019, expressed its intention for data controllers to achieve a high level of compliance with the obligations imposed by data protection regulations, fostering a culture of data protection that clearly enhances competitiveness while being compatible with economic development.

Regulation (EU) 2016/679 of the European Parliament and the Council, of April 27, 2016, concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016) (hereinafter, GDPR), provides a modernized framework based on accountability for data protection in Europe.

In this regard, Article 5, paragraph 2, of Regulation (EU) 2016/679 explicitly establishes the principle of “proactive responsibility,” whereby the data controller is responsible for compliance (and able to demonstrate it) with the following principles relating to processing:

• Personal data shall be processed lawfully, fairly, and transparently in relation to the data subject (“lawfulness, fairness, and transparency”);
• Personal data shall be collected for specified, legitimate, and explicit purposes and shall not be further processed in a manner incompatible with those purposes; according to Article 89, paragraph 1, further processing of personal data for archiving purposes in the public interest, scientific or historical research, or statistical purposes shall not be considered incompatible with the initial purposes (“purpose limitation”);
• Personal data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (“data minimization”);
• Personal data shall be accurate and, where necessary, kept up to date; all reasonable measures shall be taken to ensure that inaccurate personal data is erased or rectified without delay, in relation to the purposes for which it is processed (“accuracy”);
• Personal data shall be maintained in a form which permits identification of the data subjects for no longer than is necessary for the purposes of processing; personal data may be retained for longer periods provided they are processed solely for archiving purposes in the public interest, scientific or historical research, or statistical purposes, in accordance with Article 89, paragraph 1, without prejudice to the application of appropriate technical and organizational measures imposed by this regulation to protect the rights and freedoms of the data subject (“storage limitation”);
• Personal data shall be processed in a manner that ensures adequate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, through the use of appropriate technical or organizational measures (“integrity and confidentiality”).

In summary, the principle of “proactive responsibility” requires a conscious, diligent, and proactive approach from organizations regarding all personal data processing activities they undertake.

In this sense, the Management / Governing Body of HOTEL GRAN LAGUNA, S.L. advocates for a proactive compliance policy, aiming to actively respect the fundamental right to data protection in the pursuit of its objectives.

Consequently, this document is created to establish the policy of HOTEL GRAN LAGUNA, S.L. in relation to compliance with Regulation (EU) 2016/679 of the European Parliament and the Council, of April 27, 2016, concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), as well as Spanish personal data protection regulations (Organic Law, its development rules, and specific sectorial legislation).