Policies of the Internal Information System
The Internal Information System of **FELIU BELLAPART ABOGADOS, S.L.P.** and **CONTFISC GESTIÓN, S.L.** provides a confidential and effective means of reporting any information concerning irregular acts committed by **FELIU BELLAPART ABOGADOS, S.L.P.** and **CONTFISC GESTIÓN, S.L.**, or by their personnel, which have come to the knowledge of the reporting person in the context of an employment or professional relationship with our organisation, in accordance with the provisions of **Law 2/2023 of 20 February**.
In writing:
- By email: denuncias@feliubellapart.com
- By post, addressed to the person responsible for the Internal Information System / the organisation’s representative before SEPBLAC for information relating to FELIU BELLAPART ABOGADOS, S.L.P. and CONTFISC GESTIÓN, S.L., at PASEO MALLORCA Nº 2, ENTLO. 07012 PALMA DE MALLORCA, BALEARIC ISLANDS.
Verbally:
- At the reporting person’s request, the information may also be submitted by means of an in-person meeting with the person responsible for the System, within a maximum period of seven days from the submission of the request.
Independently of these channels, reports may be submitted through the external information channels of the competent authorities.
Once the report has been received, the person responsible for the Internal Information System shall acknowledge receipt of the report to the reporting person within a period of less than seven days, in the case of reports submitted by an identified reporting person. In all cases, the reporting person shall be informed of the rights and obligations established under the personal data protection regulations.
The person responsible for the Internal Information System shall issue a reasoned report upholding or dismissing the communication submitted and shall, in any event, provide reasons for the decision adopted. The report shall be notified to the reporting person and to the person concerned within a maximum period of three months from the expiry of the seven-day period following the submission of the communication, except in cases of particular complexity requiring an extension of the deadline, in which case the period may be extended by a maximum of a further three months.
During the processing of the report, communication and contact may be maintained with the reporting person, and additional information may be requested from that person where considered necessary.
It shall be ensured that the person concerned by the information or report is informed of its existence, as well as of the facts described therein in summary form. In addition, that person shall be informed of their right to submit written representations 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 earlier could facilitate the concealment, destruction or alteration of evidence.
The person responsible for the Internal Information System / reporting channel guarantees confidentiality to all persons who use the Internal Information System / reporting channel. Confidentiality shall also be guaranteed where the communication is sent through channels other than those established or to members of staff who are not responsible for handling it.
During the processing of the case file, the persons concerned by the communication shall have the right to the presumption of innocence, the right of defence and the right of access to the case file, as well as the same protection established for reporting persons. Their identity shall be safeguarded, and the confidentiality of the facts and data relating to the proceedings shall be guaranteed.
The processing of personal data arising from the application of this procedure shall be governed by the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights, and Organic Law 7/2021 of 26 May on the protection of personal data processed for the purposes of preventing, detecting, investigating and prosecuting criminal offences and executing criminal penalties.
The person responsible for the Internal Information System / reporting channel shall immediately refer the information to the Public Prosecutor’s Office where the facts may, on a prima facie basis, constitute a criminal offence, or to the European Public Prosecutor’s Office where the facts affect the financial interests of the European Union.
The organisation guarantees the absence of retaliation against anyone who brings a possible unlawful act to its attention, reports a breach of regulations, cooperates in its investigation or assists in resolving it.
Persons who report or disclose infringements covered by rticle 2 of Law 2/2023 of 20 February, or acts or omissions that may constitute a serious or very serious criminal or administrative offence, shall be entitled to protection measures provided that the conditions set out in **Article 35** of that Law are met. The protection measures are set out in Article 38 of Law 2/2023 of 20 February.
The report or information shall be kept at the organisation’s premises in accordance with its document filing and retention policy.
The organisation maintains a register of all reports received. Reports shall be retained only for the period that is necessary and proportionate in order to comply with the requirements imposed by Law 2/2023 of 20 February, governing the protection of persons who report regulatory breaches and the fight against corruption, and in accordance with Article 24 and the other applicable provisions of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights. cite file:16