Privacy Notice for Data Subjects whose CVs are obtained via the ICT website
1. Data Controller and purposes of this Privacy Notice
In accordance with Art. 13 of the General Data Protection Regulation (Reg. EU 2016/679) (as
implemented and to the extent applicable in Italy, Germany, France, Spain, Poland and the United
Kingdom) (“GDPR”), we inform you that your personal data and any CV that you attach will be
processed for personnel selection purposes by ICT.
ICT is made up of Industrie Cartarie Tronchetti S.p.A. and our group companies listed below. When
we mention “ICT”, "we", "us" or "our" in this Privacy Notice, we are referring to Industrie Cartarie
Tronchetti S.p.A. and the relevant company in the ICT group acting as data controller in the country
you are advancing your candidature.
Our group companies’ legal head offices are located respectively as follows:
• Industrie Cartarie Tronchetti S.p.A., Piano della Rocca 55023, Borgo a Mozzano (LU) –
• ICT Deutschland GmbH, Prinzenallee, 1 40549 Düsseldorf (DE) – firstname.lastname@example.org
• ICT France S.A.S., 100, Rue Des Camelias, 45700 Pannes – Montargis (FR) –
• Industrie Cartarie Tronchetti Ibérica S.L.U., Poligon Industrial El Espartal Km 21 El Burgo
De Ebro 50730 Zaragoza (ES) – email@example.com
• ICT Poland Sp.z.o.o., Ul. Wloska, 3 -66470 Kostrzyn N/Odra (PL) - Kontakt.Rodo@ictpl.eu
• Industrie Cartarie Tronchetti UK Limited, Wright Hassall LLP, Olympus Avenue,
Leamington Spa, Warwickshire CV34 6BF (UK) – firstname.lastname@example.org
If you have any questions about this Privacy Notice, our privacy practices and/or wish to exercise
any of your legal data rights, please contact us using the details set out above.
We will comply with the GDPR and other applicable data protection law and principles. Your data
will be used lawfully, fairly and in a transparent way, collected only for valid purposes that we
have clearly explained to you and not used in any way that is incompatible with those purposes,
relevant to the purposes we have told you about and limited only to those purposes, accurate and
kept up to date, kept only as long as necessary for the purposes we have told you about and kept
2. Processing your Personal Data
In connection with your application to work with us, we will collect, store, and use the following
categories of personal information about you:
• the information you have provided to us in your CV and any covering letter or notes; and
• the information you have provided via our website application form, including your name,
address, personal email address, date of birth, languages, education and qualifications.
We collect your personal data from you, your named referees and (on occasion) third party
background check organisations.
We will use the personal data we collect about you to:
• assess your skills, qualifications, and suitability for working with us and any specific role you
have applied for;
• communicate with you about the recruitment process;
• keep records related to our hiring processes;
• comply with legal or regulatory requirements.
• carry out background and reference checks, where applicable.
The processing of your personal data for personnel selection purposes is legally based on:
• our legitimate interests (i.e. to select and recruit new employees and to decide whether to
appoint you to work for us (which may include shortlisting you for a role, calling you to
interview and/or deciding to offer you a role within our business));
• our need to decide whether to enter into a contract of employment with you;
• if you are successful in your application, our need to take steps to enter into a contract of
employment with you.
Where you are applying to ICT Deutschland GmbH or ICT Poland Sp. z o.o., you can expressly add
your consent to allow Industrie Cartarie Tronchetti S.p.A. to retain your data for up to 5 years, for
the purposes of considering you for future roles that become available within our business.
3. Sensitive and judicial data/ legally protected categories
Please do not provide us with special categories of data. Any special categories of data which you
do provide will not be considered and will be deleted in accordance with the terms indicated in
Section 5 of this Privacy Notice and any general current rules provided by the relevant national data
protection supervisory authority.
4. Data collection, contractual consequences of non-provision of data
The provision of your CV and related personal data is necessary for us to process your personal data
in order to fulfil our purposes and carry out the activities set out above in Section 2 of this Privacy
Notice, which could lead to you eventually obtaining a position at Industrie Cartarie Tronchetti S.p.A.
or one of the other companies belonging to our group.
If you do not provide us with your personal data or you provide personal data in an incomplete or
incorrect way, we may not be able to successfully process your application.
It is important that the personal data we hold about you is accurate and current. Please keep us and
our Recruitment Partner informed if your personal data changes during your relationship with us.
5. Data security, processing methods and storage period
We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those of our employees, agents, contractors
and other third parties on a “need-to-know” basis. They will only process your personal data on our
instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breaches and will notify
you and any applicable regulator of a suspected breach where we are legally required to do so.
Subject to the remainder of this Section 5 of this Privacy Notice, if you are not selected for an
interview in the context of a specific role, your personal data may be stored for five (5) years to
consider your candidacy in the future. After five (5) years, your personal data will be deleted, unless
you tell us otherwise at any time and your choice is consistent with our legitimate interests.
Furthermore, please note the following:
• with regard to ICT Deutschland GmbH, the storage period for your personal data will be
limited to six (6) months, after which time it shall be deleted; and
• with regard to ICT Poland Sp. z o.o., your personal data will be deleted immediately after the
recruitment process is completed,
unless you have consented to the data processing pursuant to Section 2 of this Privacy Notice,
allowing us to retain your data up to 5 years. In this case, your personal data will be deleted after 5
years or your earlier withdrawal of your consent.
6. Data sharing
We will share your personal data with third parties where required by law, where it is necessary to
administer the working relationship with you or where we have a legitimate interest in doing so.
Your personal data will be forwarded to the data controller(s) within our group based in the
country(ies) you have applied to work in. Your personal data will be shared with Industrie Cartarie
Tronchetti S.p.A, for the pursuit of the purposes indicated at Section 2 of this Privacy Notice.
Your personal data may also be shared with external companies, which will collaborate with our
group companies in order to fulfil those purposes set out in Section 2 of this Privacy Notice. Such
external companies may include:
companies that provide IT, system administration and/or information management services to us;
• companies that provide professional advice to us, such as lawyers, accountants or business
• companies that provide services for the management of our website;
• companies that provide recruiting and selection services to us.
For more details on the data processors we use, you can send a request to us using the contact
details at Section 1 of this Privacy Notice.
Please note that where you select Germany as a recruiting country, your personal data will be
forwarded to ICT Deutschland GmbH, which is the data controller and the company responsible for
reviewing your personal data and making a recruitment decision about you. ICT Deutschland GmbH
will provide you with a further information notice as soon as it will receive your application.
7. International Transfers
We share your personal data within our group. This will involve transferring your data to the UK
and within the EU.
Some of the external third parties with whom we share your personal data are based in the UK
and/or in the EU, so their processing of your personal data may involve a transfer of data from: (a)
the EU to the UK and/or (b) from the UK to the EU.
We will only transfer your personal data to countries that have been deemed to provide an
adequate level of protection for personal data (i.e. the UK and countries within the EU).
8. Your rights
Under certain circumstances, you can use the relevant contact details set out in Section 1 of this
Privacy Notice in order to exercise the right to:
• request access to your personal data. This is commonly known as a “data subject access
request” and enables you to receive a copy of the personal information we hold about you
and to check that we are lawfully processing it;
• request the rectification of any errors in the personal data that we hold about you. This
enables you to have any incomplete or inaccurate information we hold about you corrected;
• request the erasure of your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to process it. You also have
the right to ask us to delete or remove your personal data where you have exercised your
right to object to processing (see below);
• request the restriction of processing of your personal data. This enables you to ask us to
suspend the processing of personal data about you, for example if you want us to establish
its accuracy or the reason for processing it;
• object to processing of your personal data where we are relying on a legitimate interest (or
those of a third party) and there is something about your particular situation which makes
you want to object to processing on this ground. You also have the right to object where we
are processing your personal data for direct marketing purposes; and
• request the transfer of your personal information to another party. This is commonly
known as the right to data portability.
We may need to request specific information from you to help us confirm your identity and ensure
your right to access the information (or to exercise any of your other rights listed above).
In the limited circumstances where you may have provided your consent to the processing of your
personal data for a specific purpose, you have the right to withdraw your consent at any time by
contacting us using the contact details set out in Section 1 of this Privacy Notice.
You also have a right to lodge a complaint with the supervisory authority for the country you are
proposing your candidature. We would, however, appreciate the chance to deal with your concerns
before you approach the supervisory authority so please contact us in the first instance.
We reserve the right to update this Privacy Notice at any time.
Last updated: 15th December 2021