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5, on the Protection of Personal Data and guarantee of digital rights (hereinafter LOPDGDD), the Director of the Spanish Agency for Data Protection C /

articles 5,6,7 and 9. " Organic Law 3/2018, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD) in its article 72, under the heading

5 December, on the Protection of Personal Data and Guarantee of digital rights (hereinafter LOPDGDD). SECOND: Article 64.1 of the LOPDGDD, provides the

the protection of natural persons in the regarding the processing of personal data and the free circulation of these data (General Data Protection Regulation

in Article 3 of Instruction 1/2006, of 8 November, of the Spanish Data Protection Agency, on the Processing of Personal Data for Surveillance Purposes through

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (LOPDGDD), when submitted to the Spanish Data Protection Agency

of the Law have been carried out.Organic 3/2018, of December 5, Protection of Personal Data and guarantee ofdigital rights (hereinafter LOPDGDD), the following

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

Organic Law 3/2018, of 5December, Protection of Personal Data and guarantee of digital rights (inhereinafter LOPDGDD), the Director of the Spanish Agency

Organic Law 3/2018, of 5 of December, on Personal Data Protection and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

Organic Law 3/2018, of 5 ofDecember, on Personal Data Protection and guarantee of digital rights (inhereinafter LOPDGDD), the Director of the Spanish Agency

established in arts. 47, 64.2 and 68.1 of Organic Law 3/2018, of December 5, Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), the Director

of the Law of Data Protection that regulates your right of access. FOUNDATIONS OF LAW FIRST: The Director of the Spanish Agency for Data Protection, in accordance

in Articles 47, 64.2 and 68.1 of Organic Law 3/2018, of December 5, on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD), for the infringement

the LOPDGDD,the Director of the Spanish Data Protection Agency is competent to initiateand to solve this procedure.IILaw 39/2015, of October 1, on the

47, 48.1, 64.2 and 68.1 of the LOPDGDD, The Director of the Agency is competent to initiate and resolve this procedure. Spanish Data Protection. Likewise

established in articles 47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights

observation on a large scale, " In this sense, the LOPDGDD determines in its article 34.1) and 3): "Appointment of a data protection officer" "1. Those responsible

what: "1. The personal data will be: (…) f) treated in such a way as to guarantee adequate security for the personal data, including protection against

Consequently, on December 18, 2020, for the purposes provided for in article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed

of Article 13.1, in relation to Articles 6.1(a) and 8.1 of the RGPD and in relation to Article 7 of Organic Law 3/2018, on Data Protection and Digital Rights

established in articles 47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights

Title VIII of the Law Organic 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (hereinafter LOPDGDD), the following

Organic Law 3/2018, of 5 ofDecember, on Personal Data Protection and guarantee of digital rights (inhereinafter LOPDGDD), the Director of the Spanish Agency

by the Spanish Data Protection Agency and based on the following FACTS FIRST: On 26/12/2018 he is admitted to the Spanish Agency for the Protection of Details

per article 6(1) GDPR, as well as article 20 of the Spanish Law on Personal Data Protection and Guarantee of Digital Rights (debtors data can only be checked

47 and 48.1 of the Law Organic 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is competent

instructed by the Spanish Agency for Data Protection and based on to the following: BACKGROUND FIRST: The Spanish Agency for Data Protection proceeded to open

Organic Law 3/2018, of 5 ofDecember, on Personal Data Protection and guarantee of digital rights (inhereinafter LOPDGDD), the Director of the Spanish Agency

imposed on public authorities under Article 37(1) GDPR. This obligation is also within Article 34(1) and (3) of the Spanish data protection law (LOPDGDD). The

art. 47, 64.2 and 68.1 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD), the Director

Article 46.1 of the aforementioned Law. 1035-150321 Mar España Martí Director of the Spanish Data Protection Agency Law 39/2015, of 1 October, on the Common

why on July 24, 2020, for the purposes provided in its Article 64.2 of the LOPDGDD, the Director of the Spanish Agency for the Protection of Data agreed

the Spanish Data Protection Agency. Likewise, article 63.2 of the LOPDGDD determines that: “The procedures processed by the Spanish Data Protection Agency

the LOPDGDD,the Director of the Spanish Data Protection Agency is competent to initiateand to solve this procedure.IILaw 39/2015, of October 1, on the

Director of the Spanish Data Protection Agency is competent to initiate and to resolve this procedure. II Law 39/2015 of 1 October on the Common Administrative

48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, on Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

Organic Law 3/2018, of 5 December, on Personal Data Protection and the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD), and against

47, 48.1, 64.2 and 68.1 of the Law Organic 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is

infraction of article 48.1.b) of the LGT Law, included in its Title III, which states that: "Regarding data protection personal data and privacy in relation

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

second, of Organic Law 3/2018, of 5 December, on Data Protection Personal and guarantee of digital rights (hereinafter LOPDGDD). THIRD: On 14 February 2020

of the Law Organic 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter LOPDGDD). SECOND: Article 64.1 of the

established in articles 47, 48.1, 64.2 and 68.1 of the Law Organic 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights

Treatment of Personal Data and the Free Circulation of these Data (RGPD) and the Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee

es 3/11 Spanish Data Protection. Likewise, article 63.2 of the LOPDGDD determines that: "The procedures processed by the Spanish Data Protection Agency

OF LAW Yo In accordance with the provisions of articles 47, 48.1, 64.2 and 68.1 of Organic Law 3/2018, of December 5, on the Protection of Personal Data

5 December, Protection of Personal Data and guarantee of digital rights (LOPDGDD), when submitted to the Spanish Agency for Data Protection a claim, it

of the personal data, and the link between the controller's activity and the processing of personal data (Article 76(1)(b) of the Spanish Data Protection

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

28001 - Madrid sedeagpd.gob.es 2/7 protection of personal data (RGPD-LOPDGDD) and Delegate Service of Data Protection, for a period of 12 months. In good

47, 48.1, 64.2 and 68.1 and 68.2 of the LOPDGDD is competent to initiate and resolve this procedure the Director of the Spanish Data Protection Agency

in which personal data corresponding to the claimed person appears, violating the regulations on data protection. The security of personal data is regulated

the LOPDGDD, the rector of the Spanish Data Protection Agency is competent to initiate and to solve this procedure. II Law 39/2015, of October 1, on the

the LOPDGDD, the Director of the Spanish Data Protection Agency is competent to initiate and to solve this procedure. II Law 39/2015, of October 1, on

evidences on such compliance. Although, according to Article 72 of the Spanish Law on Personal Data Protection and Digital Guarantees (LOPDGDD), the infringement

of Personal Data and guarantee of digital rights (hereinafter LOPDGDD). SECOND: Article 64.1 of the LOPDGDD, provides that: "one. When the procedure refers

thearts. 47, 64.2 and 68.1 of Organic Law 3/2018, of December 5, on the Protection ofPersonal Data and Guarantee of Digital Rights (LOPDGDD), the Director

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (LOPDGDD), when submitted to the Spanish Data Protection Agency

the Spanish Agency for the Protection of Data and based on the following FACTS FIRST: On 13/02/2019 he joined the Spanish Protection Agency of Data (AEPD)

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (LOPDGDD), when submitted to the Spanish Data Protection Agency

December on the Protection of Personal Data and Guarantee of digital rights (hereinafter LOPDGDD). SECOND: Article 64.1 of the LOPDGDD, provides that: "1. Where

the LOPDGDD, the Director of the Spanish Data Protection Agency is competent to initiate and to solve this procedure. II Law 39/2015, of October 1, on

by the Spanish Agency for Data Protection andbased on the followingBACKGROUNDFIRST: On June 19, 2019, he had entry into this Spanish Agency ofData Protection

47, 48.1, 64.2 and 68.1 of the Organic Law 3/2018, of December 5, Protection of Personal Data and Guarantee of Digital Rights (hereinafter, LOPDGDD), is

of the Organic Law 3/2018 of December 5, 2008, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter LOPDGDD), the following

processing the personal data of the request of the data subject to delete any link to such personal data or any copy or replica thereof. 3. Paragraphs 1 and 2 shall

established in arts. 47, 64.2 and 68.1 of Organic Law 3/2018, of December 5, Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), The Director

with articles 5,6,7 and 9. " Organic Law 3/2018, on Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD) in its article 72, under the heading

to Article 22(4) of the Spanish Law on Personal Data Protection and Digital Rights Guarantee (LOPDGDD). Additionally, the Spanish DPA found that the lack

(General Data Protection Regulation, hereinafter RGPD), recognizes each Control Authority, and as established in articles 47, 48.1, 64.2 and 68.1 of the

processing of personal data. A voice is a personal attribute unique to each person and thus falls under the definition of personal data in Article 4(1)GDPR. Furthermore

having responded to the Spanish Data Protection Agency. THIRD: On 26 September 2019, the Director of the Spanish Data Protection Agency agreed to initiate

December, Protection of Personal Data and Guarantee of Digital Rights (hereinafter LOPDGDD), the Director of the Spanish Agency of Data Protection is competent

provisions of Article 65 of Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (LOPDGDD hereinafter), the claim was

articles 47, 48.1 and 64.1 of the Law Organic 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), is competent

December, on the Protection of Personal Data and Guarantee of digital rights (hereinafter LOPDGDD). SECOND: Article 64.1 of the LOPDGDD, provides that "1. Where

the LOPDGDD, the Director of the Spanish Data Protection Agency agreed to admit the claim. THIRD: On 17 March 2020, the Director of the Spanish Data Protection

December 5, on Data Protection Personal and guarantee of digital rights (hereinafter LOPDGDD), states what: "1. In accordance with the provisions of article

Organic Law 3/2018, of 5 December, Protection of Personal Data and guarantee of digital rights (LOPDGDD), when submitted to the Spanish Data Protection Agency

identification of the data subjects during no longer than is necessary for the purposes of processing the personal data; the personal data may be kept for longer

articles 47 and 48.1 of Organic Law 3/2018, of December 5, on Data Protection Personal and guarantee of digital rights (hereinafter, LOPDGDD), is competent

December 5, 2008, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter LOPDGDD). SECOND: Article 64.1 of the LOPDGDD, provides as

article 73 of Organic Law 3/2018, of December 5, of Protection of Personal Data and guarantee of digital rights (hereinafter, LOPDGDD), which establishes

article 5.1.f) of the GDPR: "The personal data will be: “Treated in such a way as to guarantee adequate data security personal data, including protection against

[nor according Art. 37(1) GDPR nor Art. 34 of the Spanish Law on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD)], but, due to the complaint

processing the personal data of the request of the data subject to delete any link to such personal data or any copy or replica thereof. 3. Paragraphs 1 and 2 shall

of the Spanish Data Protection Agency. Likewise, article 63.2 of the LOPDGDD determines that: "Procedures processed by the Spanish Data Protection Agency

of the Spanish Data Protection Agency RESOLVES: 1. FIRST: IMPOSE COMMUNITY OF OWNERS B.B.B. with NIF *** NIF. 1, for an infringement of article 5.1 f) of

of the claims made before the Spanish Agency for Data Protection, consisting of transferring them to the Data Protection Delegates designated by those

the Spanish Data Protection Agency and on the basis of the following FACTS FIRST: On October 8, 2019, he joined this Spanish Agency Data Protection Department

provided in article 46.1 of the aforementioned Law. 938-131120 Mar Spain Martí Director of the Spanish Agency for Data Protection C / Jorge Juan, 6 www

Second Section, of Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of rights digital (hereinafter LOPDGDD). As a result of the investigative

this act, as provided in article 46.1 of the aforementioned Law. Mar Spain Marti Director of the Spanish Data Protection Agency C/ Jorge Juan, 6 www.aepd

Organic Law 3/2018, of 5 of December, Protection of Personal Data and guarantee of digital rights (in hereinafter LOPDGDD), the Director of the Spanish Agency

December 5,,onnPersonal Data Protection anddGuarantee of Digital Rights (hereinafter referred too as LOPDGDD). SECOND: Article 64.1 of the LOPDGDD, provides

Processing of Personal Data and the Free Movement of these Data (RGPD), and violation of Organic Law 3/2018, of December 5, on Data Protection Personal Rights