4.5.3. Information security. Access control

The Tax Agency has established an Information Security Policy approved by Resolution of the Presidency of the Tax Agency, dated November 8, 2012, aligned with the National Security Scheme. The Information Security Policy is the instrument used by the Tax Agency to achieve its objectives using the information and communications systems in a secure manner.

In 2019, the Tax Agency completed the adaptation of its information systems to Organic Law 3/2018 on the Protection of Personal Data and guarantee of digital rights, a rule that is specified internally by the General Data Protection Regulation (Regulation ( EU) 2016/679). Likewise, in 2019 the adaptation in terms of data protection of the systems shared between the Directorate General of Taxation and Customs Union of the European Commission and the Member States began.

Within the framework established by the Information Security Policy, the Tax Agency has information protection and security mechanisms, among which the management of users and authorizations and access control stand out, the purpose of which is eminently preventive.

This control system, driven and supervised by the Internal Audit Service, is based on the registration of accesses. Every time a user accesses the corporate information system for an enquiry or for a management activity, they must declare the reason for access. Any access to tax information of a personal nature is registered together with a series of technical and administrative data which reveal its context and facilitate subsequent control.

The accesses of greatest risk are selected and audited, in accordance with the risk analysis and the guidelines of the Tax Computing Security and Control Commission. If the controller considers that it is a serious or very serious improper access, they can initiate a disciplinary proceeding, if applicable. Currently, users with some non-compliant access have decreased to one for every 459 users audited.

In 2019, justification of some access was required for 80.71 percent of the total users of the Tax Agency. As a result of this access control, 8 disciplinary proceedings have been initiated to date.

Finally, transfers of information from the Tax Agency to public bodies, covered by article 95 of the LGT, have security and control measures equivalent to the previous ones, regardless of their supply channel.