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Privacy policy in relation to personal data relating to temperature monitoring at points of entry

Who is the data controller for personal data?

The data controller for the processing of personal data collected via portable or fixed devices for the taking of temperatures in these facilities is the Agbar Foundation, UTR G-58120353 and whose registered office is at carretera de Sant Joan Despí, 1, 08940, Cornellà de Llobregat.

If you have any query or question in relation to the processing of personal data, contact our data protection officer (DPO) at the email address


What personal data is processed?

The body temperature of data subjects will be processed with their image by portable devices (face screen) or fixed devices (thermal camera).

When body temperatures are taken with the readers, the temperature is not recorded or linked to any specific person at any time.


What is the purpose of the processing of personal data?

Personal data concerning body temperature collected by fixed and portable devices will be processed for the sole and exclusive process to allowing only individuals who do not have a particular temperature to access the facilities of the Agbar Foundation in order to protect workplace health and safety during the public health emergency caused by COVID-19 following guidance from the Department of Workplace Health and Safety of the Agbar Foundation, which in turn helps to contain the disease.


How long will personal data be retained?

The personal data obtained via fixed and portable devices will be retained for the time that is essential to carry out the required checks and will then be deleted. The personal data obtained using portable devices will not be recorded.

As an exception, the Agbar Foundation will retain a copy of the personal data for a longer time when at the time of data capture the data subject has made a complaint in relation to refusal of access to the facility or building. In that event, the personal data will be retained only for so long as required to handle the complaint or for any process or procedure that may ensue. Subsequently, the personal data will be deleted.


What is the legal basis for the processing of personal data?

The legal basis for the processing of personal data is i) compliance with the obligation that arises under Articles 14 and 18 of Law 31/1995 of 8 November on Health and Safety at Work in pursuance to which the organisation has to implement all measures required to ensure the health and safety of its workforce and third parties at its facilities and buildings, and ii) the requirement to protect the physical wellbeing of the data subject and other individuals.


What security measures have been implemented to protect personal data?

The Agba Foundation will process your personal data in an absolutely confidential manner. Consequently, it has adopted technical and organisational measures that are sufficient to ensure the security of personal data and to prevent their destruction, loss, unauthorised access and unauthorised alteration. In determining those measures, account has been taken of matters such as the scope, the context and the purpose of processing, the state of the technology and the risks that exist.


Does the Agbar Foundation disclose personal data to third parties?

Personal data will only be disclosed to third parties if required to comply with legal obligations such as notification to health authorities.


Are there other entities that may have access to your personal data?

The Agbar Foundation engages providers who assist it in the performance of different tasks relating to the processing who are required to strictly comply with the law relating to the protection of personal data through the relevant data processor contracts.


What rights do you have in relation to the protection of personal data and how can you exercise those rights?

The law confers on you the following rights in relation to the protection of personal data:




You may ask us that personal data we hold.


You may ask us to correct your personal data when they are incorrect or incomplete.


You may request us to delete your personal data.


You may request that we do not process your personal data for certain purposes.

Restriction of processing

You may request us to restrict the processing of your personal data in certain circumstances.

To make a complaint to the competent authority.

To make a complaint to the competent authority for the alternative to citizenship your rights the Spanish Data Protection Agency through the website


Those rights may be exercised by application to the Agbar Foundation either by email to the email address or by post to the address carretera de Sant Joan Despí, 1, 08940 Cornellà de Llobregat under subject “Data Protection”. Your request should contain a copy of your National Identity Document or an equivalent identity document and the minimum information required by relevant law. If your request does not meet the stated requirements, you may be asked to amend it. The exercise of those rights is free, but a fee may be charged when requests are baseless, excessive or repetitive.