Result of the resolution: Imposition of penalty
If the responsible for the file orders third one a service that implies the access to particulars, the contract of treatment person in charge that has to contemplate all of the foreseen extremes has to be formalized to the article 12 of the LOPD. For lack of the mentioned contract, the person in charge of the treatment is responsible, in turn, of a treatment il·licit of particulars. Applied articles: Arts. 6, 12, 45, 44.3.d) LOPD