Whistleblower channel

Management of personal data related to investigating complaints or queries regarding possible breaches of the company's code of ethics or regulations.
Entity in charge
C/Velázquez, 132 - 28006 MADRID (Madrid)
[email protected]
Base de licitud
The legal basis for processing is GDPR Article 6(1)(c): processing is necessary
for the fulfilment of a legal obligation applicable to the data controller: Organic Law 10/1995, of 23 November, of the Spanish Criminal Code.
terms for data retention
Data will be stored for the time necessary to comply with the purpose for which they were collected and to determine the possible liabilities that could derive from that purpose and data processing. The provisions of the file and documentation regulations applicable to Navantia will apply.
The data included in the whistleblower channel will be stored in accordance with Organic Law 3/2018, on Data Protection and Guarantee of Digital Rights, and Organic Law 10/1995, of 23 November, on the Criminal Code.
Affected groups
Employees, third parties, persons who submit complaints through the whistleblower channel and other persons affected by the complaints filed.
Data type - Infringement
Administrative offences, criminal convictions.
Data types - Special categories
Data not processed.
Data type - Identification data
Name and surname;
Tax identification number;
Photo. (*)
(*) Foreigner identification number, passport number or residence card number.
Data type - Other
Employment details; economic, financial and insurance details: profile data (social networks, financial solvency, psychological aspects); other data included in the complaint.
Security measures
The security measures applied correspond to those in Schedule II (Security Measures) of Royal Decree 3/2010, of 8 January, regulating the National Security Scheme for Electronic Administration, and described in the documents forming part of Navantia's data protection and information security policy.
Security measures corresponding to Schedule A of UNE-EN/IEC 27001 - Information Security Management Systems.
Security measure
In addition, security measures are adopted on paper documentation based on the risks to which they are exposed to ensure the confidentiality of the data processed.
Communications are envisaged when data can be communicated in accordance with Article 6 GDPR, in relation to authorised processing of:
- Courts of Justice.
- Security forces.
- Other public authorities with jurisdiction based on the complaint filed.
International transfers
They are not envisaged.