I have a legal question:

Often I see in Privacy Policies and Terms of Conditions the point/field entitled: "Holder of the treatment."

Usually in the "Holder of the treatment" field, websites puts their own physical street address / office address, and sometimes the holder puts his own name in that field.

So is it officially needed, or is it just something I can avoid adding into such legal texts?

NB: I'm Italian, so I need to follow Italian laws.

I only found this link: http://it.wikipedia.org/wiki/Titolare_del_trattamento_dei_dati But it's in Italian so sorry, and I can't understand if I need to put the "holder of the treatment" in legal text.

  • Hopefully I edited this correctly (according to the norm here). Feel free to edit it further if I missed something.
    – dan
    Commented Jun 20, 2013 at 9:41
  • Great - I have Italian friends and we always need to correct each other (me more for my Italian) :-) Glad you got an answer.
    – dan
    Commented Jun 20, 2013 at 16:51
  • @dan eheh ;) it's always a trouble writing in english i do my best as you can see :D Commented Jun 20, 2013 at 16:55
  • It was pretty good - I'd be unable to use this site at all if it were in Italian!
    – dan
    Commented Jun 20, 2013 at 16:59

1 Answer 1


I'm the founder of a service for generating privacy policies, which happens to be based in Italy, so I know very well Italian laws on the topic.

In your case and according to Italian laws, the Data Controller - Titolare del Trattamento in Italian - must be mentioned in the privacy policy (or by any other means of informing the data subject/user about its personal data), as of Art. 13.1.f (dlgs 196/2003), which states that the data subject (commonly the user) must be informed about the Data Controller's identification details.

Feel free, anyway, to use our service to avoid the pain of studying privacy laws in depth in order to comply with them :)

  • +1 thanks, before to accept your answer, do you even know if for "identification details" they mean physical owner ? just for example, Paolo has a website, spam.it, will Paolo have to put "Paolo Rossi , via antani 65 , 5400, ASD (Provincia di Supercazzola)" as owner or will Paolo be able to put only "Spam.it" as the owner without specifying any physical address? @Andrea Giannangelo Commented Jun 20, 2013 at 16:46
  • what i mean is ... is there any kind of personal data privacy for the owner himself? :) Commented Jun 20, 2013 at 16:49
  • We usually suggest to insert at least full name (or company name, if legal entity) and physical address of the Data Controller. Commented Jun 20, 2013 at 18:08

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