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Information to the interested party on data protection

5.80. Compatibility files

Description of the activity

Management of compatibility files for AEAT employees.


Personnel, civil servant and labor management, assigned to the AEAT.


Article 6 of Regulation 2016/679 (EU), relating to the legality of processing, in section 1, letter b) states that “The processing will be legal if at least one of the following conditions is met: (…) b) the processing is necessary for the execution of a contract to which the interested party is a party or for the application at the request of the interested party of pre-contractual measures (…)”.

By virtue of this precept, the processing of data is lawful, and will not require consent, when the processing of data is carried out for the fulfillment of contractual relations of an employment nature.

This provision would also cover the processing of data of public employees, although their relationship is not contractual in the strict sense.

On the other hand, the processing of data for the exercise of the sanctioning power, in which the disciplinary power is subsumed, would have its legal coverage in the reiterated article 6 of Regulation 2016/679 (EU), relating to the legality of the processing, in this case in section 1, letter e) which states that “The treatment will be lawful if at least one of the following conditions is met: (…) c) the treatment is necessary for the ( …) exercise of public powers conferred on the person responsible for the treatment (…)”.


  • People who request compatibility in public or private activity


  • NIF/DNI, Name and Surname, Address
  • Academic and professional
  • Commercial information
  • Transactions of goods and services


  • Collection
  • Record
  • Storage
  • Structuring
  • Modification
  • Update
  • Copy
  • Analysis
  • Enquiry
  • Extraction
  • Promotion
  • Interconnection
  • Limitation
  • Suppression
  • Destruction
  • Other


are not foreseen

International transfers

are not foreseen

Planned deadlines for deletion

The data collected will not be deleted and will remain in the databases of the State Tax Administration Agency (AEAT) in order to cover possible legal requirements or other types of claims that may arise.


Does not apply

Technical/organizational measures

All data processed has been evaluated through a risk analysis, having obtained a list of technical and organizational measures to apply.

These measures have been applied in accordance with the approved adaptation plan.