In the case of groups of companies, when making the calculation, should the number of workers in each company be taken into account individually or as a whole?

(Article 11)

The obligation to have an Internal Information System is attributed to natural or legal persons in the private sector that have fifty or more employees. A group of companies is a unit of economic action that is organized in several commercial companies with a common management but that, as such, does not have legal personality and, therefore, beyond what the rules provide, it cannot be subject to rights and obligations. Therefore, this calculation for the purposes of having an Internal Information System will have to be done by each of the legal entities that make up the group.

In the event that, in a group of companies, some are required to have internal information systems and others are not, it must be taken into account that art. 11 of the Law establishes that it will be necessary to approve a general policy relating to the Internal Information System and that will be necessary to ensure that it is applied to all the entities that make it up, without prejudice to the autonomy and independence of each of them, and of the modifications or adaptations necessary to comply with the applicable regulations in each case.