Introduction to the Complaints Channel - Informant Law

Welcome to the Complaints Channel that the FUNDACIÓ SITGES INTERNATIONAL FILM FESTIVAL OF CATALUNYA makes available to you in order to guarantee that all our activities comply with the principles contained in our Code of Good Governance, Ethics and Good Practices and current legislation.

This channel is available to all FUNDACIÓ SITGES workers, employees, self-employed workers, members of the Board of Trustees and Executive Committee and anyone who works under the direction of our contractors, subcontractors and suppliers. Likewise, volunteers, interns and workers in training, or even those candidates who have become aware of possible infractions or irregularities during the selection or pre-contractual negotiation process, may also report violations within the framework of an employment or statutory relationship that has already ended.

The SITGES FUNDACIÓ Whistleblower Channel allows you to safely and confidentially report any irregularity that you may notice in the development of your professional activity and actions contrary to the law or reasonable suspicions of regulatory breaches, 24 hours a day, 365 days a year.

The complaint/communication can be:

• Anonymous
• Nominative: if you decide that the complaint is nominative, we assure you that your identity will not be revealed to the accused or to third parties. Likewise, at FUNDACIÓ SITGES we reject any type of retaliation against whistleblowers/informants and against any person who participates in the investigation of the reported facts.

Notwithstanding the foregoing, the FUNDACIÓ SITGES informs you of the existence of external communication channels before the Independent Informant Protection Authority.

Whistleblowing Channel Privacy Policy - Informant Law

Responsible for the Treatment: FUNDACIÓ SITGES INTERNATIONAL FILM FESTIVAL OF CATALUNYA, with CIF G64070592 and with address at c/ Sant Honorat, 32, 08870 Sitges, Barcelona and email address administracio@sitgesfilmfestival.com (hereinafter, “FUNDACIÓ SITGES”).

Legal basis: The legal basis that enables FUNDACIÓ SITGES to process your data through the Complaints Channel is compliance with a legal obligation.

Purposes: The data of the people who present the complaints through the Complaints Channel, as well as those of the people affected by them, will be processed exclusively for the purpose of managing and processing the complaint/communication presented and, where appropriate, carry out all the necessary actions to investigate and detect possible breaches or irregular conduct that violate the principles contained in the Code of Good Governance, Ethics and Good Practices of the FUNDACIÓ SITGES and, in particular, those acts that may constitute a crime and irregularities of a labor, accounting and financial nature (which includes processing any procedure related to the facts denounced).

Confidentiality: This Complaints Channel has a series of guarantees, among which it is worth highlighting the confidentiality and confidentiality of the identity of the complainant/informant and of any third party mentioned in the complaint, as well as the option to make complaints/communications anonymously.

Recipients of personal data: In order to comply with the purposes of the treatment indicated above, FUNDACIÓ SITGES may give access to personal data to service providers (processors) who provide support in the processing of complaints/communications received. Likewise, personal data may be communicated to the Courts and Tribunals, to the Public Prosecutor's Office or to the competent administrative authority in the framework of a criminal, disciplinary or sanctioning investigation.

Conservation of personal data: The data will be kept only for the time essential to decide on the appropriateness of initiating an investigation into the reported/reported facts. In any case and in accordance with current legislation, three months after receiving the complaint/communication, we will proceed to delete it, unless the purpose of conservation is to leave evidence of the operation of this Channel of Denunias (internal information system ). Complaints that have not been processed will be recorded anonymously, without the application of the blocking obligation provided for in the LOPD-GDD.

Rights of the complainant/informant: We inform you that you can exercise your rights recognized in the regulations on data protection (access, rectification, deletion, limitation, portability and opposition) by sending an email to administracio@sitgesfilmfestival.com, indicating the subject «Data Protection-Complaints Channel».

Additionally, we inform you that if you consider that we have not properly addressed your rights, you have the right to file a claim with the Spanish Agency for Data Protection.

Access to the Complaints Channel

You can access the Complaints Channel that the FUNDACIÓ SITGES INTERNATIONAL FILM FESTIVAL OF CATALUNYA makes available to you through the following link: COMPLAINTS CHANNEL