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Whistleblowing channel

Purpose
Management of personal data related to the investigation of complaints or inquiries regarding behaviors, actions, or omissions that may constitute a violation of the regulations applicable to Navantia or the commission of acts constituting a crime or administrative offense.
Entity in charge
NAVANTIA S.A. S.M.E.
A84076397
C/Velázquez, 132 - 28006 MADRID (Madrid)
(+34) 913 358 400
[email protected]
[email protected]
Base de licitud
The legal bases for processing are:

Article 6.1.c) of GDPR: Processing is necessary for compliance with a legal obligation to which the controller is subject:
- Organic Law 10/1995, of November 23, of the Penal 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 data included in the Whistleblowing Channel will be retained in accordance with Organic Law 3/2018, on Data Protection and Guarantee of Digital Rights, Organic Law 10/1995, of November 23, of the Penal Code, and Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and fight against corruption.
Affected groups
Employees; Clients; Suppliers.
Data type - Infringement
Administrative offenses and criminal convictions.
Data types - Special categories
Data not processed.
Data type - Identification data
Name and surname; NIF*; Image; Telephone; Email.
(*) NIE, Passport, or Residence card number.
(**) Handwritten or electronic.
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
Additionally, security measures are adopted for paper-based documentation according to the risks to which they are exposed, in order to ensure the confidentiality of the processed data.
Communication
Communications are foreseen when data can be communicated in accordance with Article 6 of GDPR, in relation to authorised processing of:

- Courts of Justice.
- Security forces.
- Other public authorities with jurisdiction based on the complaint filed.
International transfers
Not foreseen.