Internal Information System Policies.
The Internal Information System of COMPAÑÍA BALEAR EXHIBICIÓN CINEMATROGRÁFICA S.L is the channel to communicate, confidentially and effectively, any information about irregular acts committed by COMPAÑÍA BALEAR EXHIBICIÓN CINEMATROGRÁFICA S.L or its personnel, which have been known within the framework of an employment or professional relationship maintained with our organization in accordance with the provisions of Law 2/2023, of February 20.
The organization has configured the Internal Information System through the following channels:
In writing:
- Through the following link: https://aficine.com/sistema-interno-de-informacion/
- By postal mail, addressed to the Person Responsible for the Internal Information System of the organization COMPAÑÍA BALEAR EXHIBICIÓN CINEMATROGRÁFICA S.L at CALLE BISBE PERE PUIGDORFILA Nº1, 07010, PALMA DE MALLORCA, BALEARES.
Whistleblowing channel
Verbally:
- At the request of the reporting person, the information may also be submitted through an in-person meeting with the Person Responsible for the System, within a maximum period of seven days from the submission of the request.
– Apart from these channels, communications may be submitted through the external information channels of the competent authorities:
Independent Authority for the Protection of the Reporting Person through the email address canal.externo@proteccioninformante.es
You can find more information on the website: https://www.proteccioninformante.gob.es/.
-Once the report has been received, the person responsible for the Internal Information System will acknowledge receipt of the report to the reporting person within a period of less than 7 days –in the case of identified reports–. In any case, the reporting person will be informed of the rights and obligations established by personal data protection regulations.
-The person responsible for the Internal Information System will issue a reasoned report that will either uphold or dismiss the submitted communication, justifying, in any case, the decision adopted. The report will be notified to the reporting person and the affected person within a maximum period of 3 months from the expiry of the seven-day period after the communication has been made, except in cases of special complexity that require an extension of the period, in which case it may be extended for a maximum of an additional three months.
-During the processing of the report, communication and contact with the reporting person/complainant may be maintained and, if considered necessary, additional information may be requested from the reporting person.
-It is guaranteed that the person affected by the information or report will be informed of it, as well as of the facts described in a concise manner. Additionally, they will be informed of their right to submit written allegations and of the processing of their personal data. However, this information may be provided during the hearing stage if it is considered that providing it beforehand could facilitate the concealment, destruction or alteration of evidence.
-The person responsible for the Internal Information System/Whistleblowing Channel guarantees confidentiality to all those who use the Internal Information System/Whistleblowing Channel. In addition, confidentiality is guaranteed when the communication is sent through reporting channels other than those established or to staff members not responsible for its processing.
-During the processing of the case, the persons affected by the communication will have the right to the presumption of innocence, the right of defense and the right of access to the file, as well as the same protection established for reporting persons, preserving their identity and guaranteeing the confidentiality of the facts and data of the procedure.
-The processing of personal data derived from the application of this procedure will be governed by the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, Organic Law 7/2021, of May 26, on the protection of personal data processed for the purposes of prevention, detection, investigation and prosecution of criminal offenses and the execution of criminal penalties.
-The person responsible for the Internal Information System /whistleblowing channel will immediately forward the information to the Public Prosecutor’s Office when the facts could constitute a criminal offense or to the European Public Prosecutor’s Office if the facts affect the financial interests of the European Union.
-The organization guarantees the absence of retaliation against anyone who reports a possible unlawful conduct or has communicated a regulatory breach or collaborates in its investigation or helps to resolve it.
-Persons who report or disclose infringements included in Art.2 of Law 2/2023, of February 20, and actions or omissions that may constitute a criminal or serious or very serious administrative offense, will have the right to protection measures provided that the conditions set out in Article 35 of said law are met. The protection measures are set out in Article 38 of Law 2/2023, of February 20.
-The report or information will be kept in the organization’s facilities in accordance with its document archiving and retention policy.
-The organization maintains a register of all reports received. Reports will only be kept for the period necessary and proportionate to comply with the requirements imposed by Law 2/2023, of February 20, on the protection of persons who report regulatory infringements and on the fight against corruption, and in accordance with the provisions of Article 24 and other applicable articles of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights.
