LD Consultores

Statement of Arrangements

Safeguarding Individual Rights: Statement of Arrangements

JAN 2026

Entity: LD Consultores C.A.

Subject: Data Protection Safeguards for Candidates, Employees, and Contractors.

LD Consultores C.A. recognises that personal data is the property of the individual. To protect the rights and freedoms of the data subjects we process on behalf of our clients, we have implemented a multi-layered framework of legal, technical, and organisational safeguards.

1. Legal and Contractual Safeguards

  • Transparency and the Right to be Informed: We provide all data subjects with a clear and concise Privacy Notice at the point of collection. This notice outlines the identity of the controller, the specific purpose of processing (e.g., EOR or Payroll), and their statutory rights under Venezuelan and international law.
  • Data Processing Agreements (DPAs): We operate strictly as a Data Processor for our clients. Our arrangements include robust DPAs that prohibit the use of personal data for any purpose outside the scope of the agreed service.
  • International Transfer Protections: For data movements involving international jurisdictions, we utilise Standard Contractual Clauses or equivalent International Data Transfer Agreements to ensure that the data receives the same level of protection regardless of geographic location.

2. Technical Safeguards (Privacy by Design)

  • Encryption and Data Integrity: All personal and sensitive information (including bank details, RIF/ID numbers, and contact info) is encrypted using AES-256 standards both “at rest” (on our servers) and “in transit” (when sent via secure channels).
  • Access Control and Segregation of Duties: We apply the “Principle of Least Privilege.” Access to sensitive employee files is restricted via role-based permissions and protected by Multi-Factor Authentication (MFA). Our internal systems ensure that a recruiter cannot access payroll data, and an accountant cannot access medical records.
  • Data Minimisation: Our systems are configured to collect only the “adequate, relevant, and necessary” data required to fulfill our labour and tax obligations 

In Venezuela, preventing the accumulation of excessive personal information.

3. Organisational Safeguards and Procedures

  • Rights Request Management (Habeas Data): We maintain a formal “Data Subject Rights Procedure.” This allows individuals to exercise their rights to access, rectify, or delete their data expeditiously. In compliance with the Venezuelan Constitution (Art. 28), we ensure that any request for data correction is handled within 48 business hours.
  • Confidentiality and Training: Every employee of LD Consultores C.A. is contractually bound by a Non-Disclosure Agreement (NDA). Furthermore, all staff undergo annual Data Protection and Cyber-Security awareness training to ensure they can identify and prevent potential rights violations.
  • Impact Assessments: For any high-risk processing activity, LD Consultores conducts a Data Protection Impact Assessment (DPIA) to identify and mitigate risks to individuals before the processing begins.

4. Summary of Individual Rights Supported

LD Consultores C.A. guarantees the following rights through our established arrangements:

  • Right of Access: Individuals can request a copy of their personal file at any time.
  • Right to Rectification: We maintain a dedicated support channel for employees to update their personal or financial information.
  • Right to Confidentiality: Medical data (under LOPCYMAT) and financial data are treated as “Special Category” and are never shared without explicit authorisation or legal mandate.

Certified by:

The Compliance Department

LD Consultores C.A.

PERSONAL DATA ACCESS & RIGHTS REQUEST FORM

Entity: LD Consultores C.A.

Instruction: Please complete this form if you wish to exercise your rights regarding the personal data held by LD Consultores C.A. Once completed, please submit this form to compliance@ldconsultores.com.

1. APPLICANT DETAILS

  • Full Name: _________________________________________________
  • ID Number (Cédula/Passport): _______________________________
  • Email Address: _____________________________________________
  • Relationship to LD Consultores: ( ) Current Employee ( ) Former Employee ( ) Candidate ( ) Other: ________

2. TYPE OF REQUEST

Please check the box that corresponds to the right you wish to exercise:

  • [ ] Right of Access: I would like a copy of the personal data you hold about me (e.g., payroll records, employment contract).
  • [ ] Right to Rectification: I believe my data is inaccurate or incomplete and I would like it updated.
  • [ ] Right to Erasure / “Right to be Forgotten”: I would like my data deleted (Subject to statutory tax/labor retention periods).
  • [ ] Right to Restriction/Objection: I would like to limit how my data is used for a specific purpose.

3. DETAILS OF THE REQUEST

To help us locate your information and fulfill your request quickly, please provide specific details (e.g., “I need my payroll stubs from January 2024 to June 2024” or “My RIF number is incorrectly recorded”):

4. IDENTITY VERIFICATION

To protect your privacy and ensure we do not disclose data to the wrong person, please attach a clear copy of your Government-issued ID (Cédula or Passport). Your request will not be processed until your identity is verified.

5. DECLARATION

I certify that the information provided in this form is correct and that I am the person to whom the personal data relates. I understand that LD Consultores C.A. may need to contact me for further clarification.

  • Signature: ____________________________ Date: ___ / ___ / 2026

INTERNAL USE ONLY (COMPLIANCE DEPARTMENT)

  • Date Received: ________________________
  • Identity Verified? [ ] Yes [ ] No
  • Deadline for Response (48 hours/30 days): ________________________
  • Action Taken: _________________________________________________