Job Applicant Privacy Policy
This application management system (“Careers Site”) is provided by ICE International Copyright Enterprise Germany GmbH (“ICE GmbH”), Lützowstraße 100, 10785 Berlin, Germany. The Careers Site allows you to apply directly to job vacancies at ICE International Copyright Enterprise Germany GmbH and its affiliated company International Copyright Enterprise Services Limited (together, “ICE”).
ICE is committed to respecting your privacy and protecting your personal data during your application process. This Job Applicant Privacy Policy (“Policy”) describes how we handle and protect your personal data in connection with ICE’s recruiting processes.
1. DATA CONTROLLER
The entity responsible for collecting, processing, and using your personal data in accordance with data protection law is ICE International Copyright Enterprise Germany GmbH, Lützowstraße 100, 10785 Berlin.
2. COLLECTING, PROCESSING, AND USING YOUR PERSONAL DATA
2.1. PERSONAL DATA
For the purposes of managing your application, we collect, process, and use your personal data that you have disclosed to us in several ways including but not limited to: via online application forms, by sending us your CV or in the interviews that we hold to assess your skills and profile. We may also engage in candidate headhunting in order to fill certain positions so we may collect and process personal data available from public sources, such as the information available in your LinkedIn profile or similar public sources.
Personal data means any information that relates to an identified or identifiable individual person. Personal data we may collect includes:
- Name, address, telephone number, e-mail address and other contact information;
- Passport or other ID documents information;
- Work authorization status and citizenship;
- CV, résumé, cover letter, previous work experience and education information;
- Skills;
- Professional and other work-related licenses, permits and certifications held;
- Information relating to references; and
- Any other information you elect to provide to us (e.g., employment preferences, current and desired salary, awards or professional memberships, photos, name of referrer).
In general, you decide yourself which data you are willing to enter and share with us. However, if you do not provide us with your personal data relevant to the application process, we may not be able to process your application or assess it properly. In addition, it is your responsibility to ensure that the information you submit does not violate any third party’s rights.
We discourage you from providing to us personal data that may be considered sensitive personal data such as your racial or ethnic origin, marital status, political opinions, religion or other beliefs, health, criminal record or trade union membership. If you provide us with this information, we will handle this information responsibly and we will need your explicit consent to process it (art. 9 (2) (a) GDPR).
2.2 HOW WE COLLECT YOUR PERSONAL DATA
For the purposes of managing your application, ICE may collect personal data from you in a variety of ways. For example, data might be contained in the online application form, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
In your application you may also provide us a link to your profile on Linkedin, XING or similar job sites and social media platforms. However, this Policy does not address, and we are not responsible for, the privacy, information or other practices of any other third-party operating any website or service to which this Careers Site links.
2.3 HOW WE USE YOUR PERSONAL DATA
We collect and process your personal data in order to process your application and assess your application against our open positions (Art. 6 (1) (b) GDPR). This also includes using the data to contact you.
We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process (Art. 6 (1) (f) GDPR). Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend legal claims.
In some cases, we need to process data to ensure that we are complying with our legal obligations (Art. 6 (1) (c) GDPR). For example, we are required to check a successful applicant’s eligibility to work in Germany or the UK before employment starts.
If we hire you, personal information we collect in connection with your application may be incorporated into our human resources system and used to manage the new-hire process; any such information can become part of your employee file and used for other employment-related purposes.
2.4 DISCLOSURE AND TRANSFER OF INFORMATION
We will only allow access to your personal data to those at ICE who require such access for the purposes of the recruitment process. This includes members of the People & Culture and Legal teams, the Works Council (for positions at ICE GmbH), interviewers involved in the recruitment process, and managers in the business area with a vacancy. If you have been referred for a job at ICE by a current ICE employee, with your consent, we may inform that employee about the progress of your application and let them know the outcome of the process.
We may share your personal data between ICE affiliates that are involved in evaluating candidates for a given position. If we share your personal information with an affiliate located in another country in its capacity as a potential employer, the affiliate will handle your personal information in accordance with this Policy. Any hiring or other employment-related decisions will be made by the hiring affiliate in accordance with the laws of the country where the job will be located. This means that when you enter into an employment contract with one of our affiliates, said affiliate will handle your personal data as the Data Controller of your personal data under GDPR or UK GDPR and local data protection regulations.
2.5 SERVICE PROVIDERS AND CROSS-BORDER DATA TRANSFERS
We may also share your personal data with third parties that provide services to us. When we share data with third-party providers we rely on data processing agreements to protect the confidentiality, availability, and integrity of your personal data (art. 28 GDPR).
During the recruitment process, your personal data may be shared with the following third parties:
(a) Greenhouse Software, Inc., a cloud services provider located in the USA and engaged by ICE to help manage our recruitment and hiring process on our behalf; and/or
(b) External legal firms based in Germany or the UK, in order to assess your work authorisation status if applicable.
We will not sell or market any of the information you provide during the recruitment process.
In the course of evaluating your application, we may need to transfer your personal data to locations outside of the EU and the UK, where our affiliates, partners, or third-party service providers are located. Such transfers are only conducted to facilitate our recruitment process, evaluate your qualifications, and, where necessary, communicate with you.
When transferring your personal data outside the EU and UK, we ensure that an adequate level of protection is maintained in accordance with GDPR/UK GDPR requirements. Specifically, we will:
1. Rely on Adequacy Decisions: when possible, transfer your data to countries deemed by the European Commission or the UK Secretary of State as providing an adequate level of data protection.
2. Implement Standard Contractual Clauses (SCCs) and International Data Transfer Agreements (IDTAs): where no adequacy decision applies, we will use the European Commission’s SCCs for EU-based transfers or the UK’s IDTAs for UK-based transfers, which legally bind our partners or service providers to GDPR-compliant data protection standards.
3. Data Protection Certifications – when applicable, we may rely on data protection certifications (such as the EU-U.S. Data Privacy Framework) to ensure that the receiving organisation complies with similar data protection standards.
4. Obtain your consent or apply other GDPR-compliant mechanisms: in limited cases, we may ask for your explicit consent for specific transfers or rely on other legally approved mechanisms to safeguard your personal data.
You have the right to request more information about the safeguards we use to ensure the protection of your personal data during such international transfers. For any questions, please contact us at data.protection@iceservices.com.
3. SECURITY
Suitable technical and organizational measures are in place to ensure that your personal data is handled confidentially and securely in accordance with the legal requirements.
4. DATA RETENTION
Your data will initially be processed exclusively for the purpose of the application procedure. If your application is unsuccessful, we will hold your data on file for a maximum of 6 (six) months after the end of the relevant recruitment process. After this period, your personal data will be deleted, unless you have given us your express consent to keep your personal data for a longer period. You can always request us to delete your data by sending an email to data.protection@iceservices.com. Please note that doing so means that you are withdrawing from any still on-going application process.
5. TALENT POOL
After the completion of the application process, you may be informed by ICE about other positions that may fit your profile. Should you wish to use that option, we will ask for your consent, in order for your data (such as contact information, qualifications, years of professional experience etc.) to be stored by us for another retention period.
Your consent is not open-ended. At the end of the retention period, we will ask you again whether you still want to be part of our talent pool. You have the option to withdraw your consent: if you do so, your data will be deleted automatically. If we don’t hear from you or if you ask us to delete your personal data, your personal data will be deleted accordingly.
You can always request us to delete your data from our talent pool by sending an email to data.protection@iceservices.com. Please note that doing so does not necessarily mean that we will not contact you again in the future as ICE has a legitimate interest in finding the right candidates and we assume that if you made your data public (e.g. in social media or on a job site), it is reasonable to expect that you are happy to be informed about positions that may fit your profile. As long as you maintain a public profile, our recruiters may find it and potentially contact you again to inform you about open vacancies at ICE, even if we have received a request from you to delete your data in the past.
6. HOW YOU CAN ACCESS, AMEND OR DELETE YOUR PERSONAL DATA
Under GDPR, UK GDPR and additional applicable German and UK data protection regulations and laws, you have rights as the data subject, which you can exercise in relation to the information we hold about you in relation to your application. You can request details of which personal data we have stored about you, at any time and, if necessary, demand its correction and/or deletion and/or restriction of processing and/or blocking. For this purpose and/or to obtain further information about it, you may contact us at data.protection@iceservices.com. The same applies if you have any questions, comments or inquiries concerning the processing of your personal data by ICE. If you have a complaint about the way in which we are managing and processing your personal data, you also have a right to lodge a complaint with a data protection supervisory authority (e.g. Federal Commissioner for Data Protection and Freedom of Information in Germany).
7. INFORMATION ON COOKIES
We use “cookies” on the Careers Site. Please see the Cookie Policy for more information.
8. CONTACT INFORMATION
If you have any questions regarding this Policy or our handling of your data, please contact our ICE GmbH Data Protection Officer:
Data Protection Officer
ICE International Copyright Enterprise Germany GmbH
Lützowstraße 100
10785 Berlin
Germany
Tel: +49 (0) 30 2089867-10 / Email: data.protection@iceservices.com
9. UPDATES TO THIS PRIVACY POLICY
Privacy laws and practice are constantly developing. Our policies and procedures are therefore under continual review. We may, from time to time, update our Policy. Any such changes will be posted on this page.
This Policy was last reviewed in October 2024.
More information on how we process personal data on our website (www.iceservices.com) can be found in our website Privacy Policy.