Data protection
For AML-relevant identification and due diligence data no consent is needed: the processing rests on the statutory obligation under Ley 10/2010 and on Art. 6, para. 1, point c, GDPR. Clients must be informed of that processing before the business relationship is established or an occasional transaction is carried out. The data may not be reused for marketing or other purposes without a legal basis of its own.
Four points order the data protection side:
Legal basis: Ley 10/2010, Art. 32 bis; GDPR, Art. 6, para. 1, point c, 13, 14; LOPD-GDD
Practical tip: Add a standard paragraph on AML data processing to your agency agreement.
AI-assisted tools were used in preparing these FAQs; the content was subsequently reviewed and approved by the Doxario editorial team. They reflect the general state of the law as at the review date shown and do not constitute individual legal or tax advice. To assess your own case — particularly where complex structures are involved (offshore companies, trusts, foundations, communities of heirs) or where the new EU rules leave room for doubt — we recommend consulting a lawyer specialising in Spanish anti-money-laundering law and, on tax questions, a tax adviser. Doxario is a deal management and compliance platform for estate agents in Spain, operated by Blue Pepper S.L.; we therefore have an economic interest in the solutions described in these FAQs. Doxario accepts no liability for decisions taken solely on the basis of these FAQs.
← Frequently asked questions