Code of conduct related communications


  • Management and archiving of communications made by employees of the Bank of Spain in relation to the obligations set forth in the code of conduct, including the reporting of possible breaches of said obligations by employees or the processing of voluntary leaves of absence for employees who decide join supervised entities or the financial sector.
  • Handling and recording-of resolutions issued by the Conflicts of Interest Office relating to compatibility requests made by employees.

Legal basis

  • Performance of a contract to which the data subject is party.
  • Compliance with a legal obligation to which the controller is subject pursuant to Law 53/1984, of 26 December, of incompatibilities of public employees and Royal Decree - Law 598/1985, of April 30, on incompatibilities of personnel at the service of the State Administration, Social Security and dependent Entities, Organizations and Companies

Categories of data subjects

  • Employees

Categories of personal data

  • Identification data: Name, surname, ID number
  • Contact data: Phone number, e-mail
  • Academic and professional data: Professional position, employee number, administrative unit
  • Economic and financial data: Salary, transactions, financial information
  • Others: Conflict of interests, activities, gifts and details relating to the code of conduct

Retention period

Personal data shall be retained for the time necessary to fulfil the purpose for which they were collected and to allocate any liability arising from said purpose and from the processing of the data.

Security measures

Security measures provided for in Annex II of Royal Decree 3/2020, of 8 January, which regulates the National Security Scheme in the field of Electronic Administration.


  • Conflicts of Interest Office
  • Courts of Justice
  • ECB
  • Other competent public authorities

International transfer of data


Data controller

Banco de España

NIF: Q2802472G

Data Protection Officer

Division of Governance and Transparency

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