The English version of this text is intended to assist the reader’s understanding, but is not legally binding. The official German version takes precedence in all matters.
The University of Stuttgart uses the messaging service Facebook via the technical platform and the services of Facebook Inc, 1601 Willow Road Menlo Park, CA 94025: https://www.facebook.com/facebookhandle/
The body responsible for the data processing of persons who live outside of the United States is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
We wish to inform you that you are using the Facebook fanpage provided on this site and its functions under your own responsibility. This applies to the use of the interactive functions in particular (for example share, rate, comment, integrate). Alternatively, you can also access study or employment information on our Internet service, www.uni-stuttgart.de
1. Data which is processed by Facebook:
Information concerning which data is processed by Facebook and for what purposes, can be found in the data protection declaration of Facebook: https://www.facebook.com/privacy/explanation
Facebook Ireland Ltd has undertaken to comply with the principles of the EU-US Privacy Shield. More information can be found via the following link: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC
The University of Stuttgart has no control over the scope of the data which is processed by Facebook or the type of processing and the use or disclosure of the said data to third parties. The University of Stuttgart also does not have any effective control options in this regard.
When using Facebook, your personal data will be recorded, transferred, saved, disclosed and used by Facebook Ireland Ltd and will then, regardless of your place of residence, be transferred to the United States and any other country in which Facebook Ireland Ltd maintains a commercial presence and will be saved and used there.
During this process, Facebook processes the data which you have provided voluntarily on the one hand, such as your name and username, email address, telephone number and the contacts in your address book (should you upload or synchronize these)
and on the other hand, Facebook also evaluates the content which you have shared, the topics you are interested in, it saves and processes confidential messages which you send directly to other users and can determine your location by means of GPS data, information concerning wireless networks and via your IP address, in order to provide you with advertising or other content.
For evaluation purposes, Facebook Ireland Ltd may use analysis tools, such as Facebook Insights or Google Analytics. The University of Stuttgart has no influence over the use of such tools by Facebook Ireland Ltd and has not been informed of such potential use. Should such tools be used by Facebook Ireland Ltd for the account of the University of Stuttgart, we have not requested or approved such use, nor have we supported this in any way. The personal data which is gathered during the analysis is not made available to the University of Stuttgart. Only specific, non-personal, aggregated information concerning the activity, such as the number of profile or link clicks on a specific post or the site can be viewed by the University of Stuttgart via its account. Furthermore, it is not possible for the University of Stuttgart to prevent or suspend the use of such tools in its Facebook fan profile.
Facebook is then informed when you view content as an example, even if you have not created an account. This so-called “log data” can consist of the IP address, the browser type, the operating system, information concerning the previously accessed website and the sites visited by you, your location, your cellphone provider, the end device used by you (including device ID and application ID), the search terms used by you and cookie information.
Via Facebook buttons or widgets which are integrated into websites and by using cookies, it is possible for Facebook to record your visits to these websites and to assign such visits to your Facebook profile. On the basis of this data, content or advertising can be tailored to you.
Even though Facebook Ireland Ltd is a provider headquartered outside of Europe which only maintains a presence in Ireland, it is still bound by the GDPR. For example, this regulates your rights of information and the right to have your data blocked or erased.
You have the option of restricting the processing of your data under the general settings of your Facebook account under the various menu settings.
Further information concerning these points can be found on the following Facebook support site:
You can find information concerning the option to view your own data at Facebook and download it via the following link: https://www.facebook.com/settings?tab=your_facebook_information
Information concerning the way in which you can be traced by Facebook can be found here:https://www.facebook.com/settings?tab=your_facebook_information
Information concerning the available personalization and data protection settings can be found here: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen and here https://www.facebook.com/settings?tab=facerec
You also have the option of getting in touch with the data protection officer of Facebook via the Facebook data protection form: https://www.facebook.com/help/contact/540977946302970
Information concerning your rights of objection in relation to the data processing by Facebook can be found here: https://www.facebook.com/help/2069235856423257
2. Data processed by the University of Stuttgart
The University of Stuttgart also processes your data, however it does not itself gather any data via your Facebook account. The data provided by you to Facebook, in particular your username and the content published under your account is however processed by us when we share or comment on your posts or when we record posts which relate to your account. Any data which you freely publish and distribute in Facebook will be included by the University of Stuttgart in its services and made accessible to its subscribers.
3. Rights, documentation, evaluation:
The concept which forms the basis of the service can be found via the following Internet address: Facebook use concept
Further information concerning Facebook and other social networks, as well as information as to how you can protect your data can also be found at Youngdata.
Should you have any questions relating to our information services, you can contact us by email. You can claim your rights of information, blocking or the erasure of data by contacting our data protection officer.
The University is characterized by its community of academic staff and students, the right of self-administration with the option of creating and carrying out one’s own study plans and research projects, as well as the authority to award publicly recognized academic titles. The University of Stuttgart is one of the leading technical universities in Germany, with a global reputation. It sees itself as a key player in university research, research which takes place outside of a university setting and industrial research, as well as a guarantor of quality and holistic, research-driven teaching. Public relations work is part of the University and will also take place in future via Facebook.
1. Facebook
Facebook is a social network for the sharing of text contributions, photos and videos. Here, registered users can upload, comment on, like and share texts, pictures and videos free-of-charge. The content can generally be viewed by anybody. Users can also send private messages or join groups in various topic areas and take part in discussions.
Further information concerning Facebook can be found here: https://www.facebook.com/pg/FacebookDeutschland/about/
Facebook provides the following benefits:
- We can show contributions to multiple users in a speedy and uncomplicated manner at the same time.
- Our target groups include many Facebook users.
- Direct initial contact to our worldwide target group (direct message)
- We can plan and communicate events
- We can place adverts
- Allows us to promote ourselves fully externally.
2. Purpose of use
By setting up a Facebook channel, the existing communication channels such as the homepage, press releases and print products are complemented in a practical way The Facebook channel enables us to communicate with specific target groups and promotes the interaction and communication with the users. By means of this, we can respond to individual queries and needs of the target groups in a service orientated manner.
For certain target groups, the existing instruments are no longer sufficient. When taking the target group of students into account, we have found that more of these people can be reached more directly, more quickly and in a more up-to-date manner via Facebook and interested recipients can like our Facebook site and subscribe to it.
We can also transport our content across various medias and improve our visibility on the Internet, and we can position our brand and increase awareness of the University of Stuttgart.
3. Type and scope of use
The Facebook account informs the user of current topics in the areas of university studies and research. In addition, it establishes interaction between students and university communications and it provides students with the option of getting in touch with university communications personally by means of direct messaging.
The regular content of the contributions includes the following:
- Current information concerning semester dates, such as re-registration and registration for examinations
- Current information concerning upcoming events at the university
- Information about student activities
- Information about changes on campus
- Information concerning current research plans and research projects
- Requesting responses and interaction with students about current topics
4. Responsibilities for editorial / technical support
The editorial support is the responsibility of the University Communications of the University of Stuttgart.
5. Alternative contact options
We wish to inform our users that the Facebook channel is only one of many options for getting in touch with the University of Stuttgart or receiving information from us.
Further contact options:
- You can generally contact the central post room with any questions you may have.
Please note: Communication by email takes place without encryption as standard. When communicating by email, it cannot be excluded that unauthorized persons become aware of the content of an email when it is being sent.
Therefore, please use the encryption option when sending confidential information.
- Should you have any telephone queries, we can be contacted on +49 (0) 711 / 685-0 (the switchboard is manned from Monday to Friday from 6.45 am to 11.30 am and from 12.30 pm to 3.30 pm).
- Building and parcel address
Keplerstr. 7, 70177 Stuttgart
- Mailing address
Postfach 10 60 37 70049 Stuttgart
6. Self-obligation
This use concept is evaluated once per calendar quarter in relation to whether and how the use takes place. We promote awareness on the part of the users concerning the risks to their right of informed self-determination.
Please also consult our social media guide, our data protection declaration and the assessment of the consequences of the use of Facebook.
A data protection consequence assessment must be carried out in accordance with the general rules of Article 35 Paragraph 1 of the European General Data Protection Regulation (GDPR) if a form of processing, in particular when using new technologies can be expected to represent a significant risk to the rights and freedoms of natural persons, in particular due to the type, scope, circumstances and purposes of the processing. The guidelines of the state officer for data protection and freedom of information (LfDI) concerning the use of social networks by public bodies imposes an obligation to carry out an assessment of the expected consequences of the intended processing for the protection of personal data in line with the GDPR.
The Facebook service of the University of Stuttgart does not represent such risks, as we only process data to a very limited extent (see also the data protection declaration of Facebook). However, postings often have a direct connection to other persons. Therefore, when creating and publishing its own content, the University of Stuttgart ensures that alongside the copyright in relation to the photos, the image rights of the persons being shown are also protected. Should other Facebook users be referred to in contributions of the University of Stuttgart (by sharing or mentioning), only the data which the person has provided voluntarily himself or herself (username and postings) is processed.
However, from the point of view of the University of Stuttgart, the use of Facebook represents processing with a significant risk due to its wide ranging effects, in particular in relation to the evaluation of the data by Facebook Ireland Ltd for advertising purposes and others for which a data protection consequence evaluation needs to be carried out due to the joint responsibility of the site operator (University of Stuttgart) and the service provider (Facebook).
Since by means of the use of a Facebook account, the respective user submits to the comprehensive observation of Facebook Ireland Ltd. During this process, sensitive data such as political views, sexual orientation and health problems may also be disclosed, connected with each other and be used to create a personality profile. Persons subject to special protections, such as young people can also be Facebook users and therefore data subjects. Even when reading Facebook in a purely passive manner without holding an account, sensitive data can be gathered through the obtaining of log data, for example by means of the previously visited websites or the location data of the user.
This applies even more when it is considered that this cannot be checked by Facebook Ireland Ltd and it can only be verified in a limited manner. As the data of German users is not processed in Germany, but rather in Ireland, there are major hurdles concerning redress before the courts compared to cases where the company is located in the country.
The University of Stuttgart proceeds on the assumption that public bodies which use a social network for public relations work and to provide general information must assume co-responsibility.
Co-responsibility does not mean that the University of Stuttgart is confirming or guaranteeing that the products of Facebook Ireland Ltd conform with data protection regulations. It is not possible for the University of Stuttgart to do so under the current circumstances. Rather, co-responsibility means that the University of Stuttgart is aware of the risks of social networks and makes others aware of these too. Currently, the social networks are considered to be in need of improvement from a data protection legislation point of view. Therefore, the Facebook users are shown alternative communication channels which better comply with data protection legislation by means of references on the homepage of the University of Stuttgart.
The risks which generally arise in connection with the use of social media are also explained to the users in the data protection declaration of the data protection declaration Facebook fanpage of the University of Stuttgart.
The University of Stuttgart has undertaken to carry out these measures in its use concept. In accordance with the use concept, the benefits and drawbacks of the use of Facebook are evaluated regularly, with the inclusion of the terms and conditions of use of Facebook Ireland Ltd.
Therefore, the use of Facebook is included in a package of measures. The assessment of the consequences of the use of Facebook by the University of Stuttgart can be explained as follows, taking the above into account:
1) Risk identification:
The risks referred to above which are connected to the use of Facebook generally exist regardless of the use of Facebook by the University of Stuttgart. Also, in the majority of cases of the postings by the University of Stuttgart, no connection is made to personal data, but rather its own, factual content is distributed.
Finally, the data which is processed by means of the interaction with the Facebook fanpage of the University of Stuttgart or other accounts- namely the account name of a Facebook user which is visible in the comments - is already public / generally accessible / freely available on the Internet.
However, by means of the appearance on the Facebook fanpage of the University of Stuttgart and the interaction, this data is made available to a wide ranging / "specific” target public audience, which means greater awareness and greater distribution than would be the case without such interaction. This also indicates the interest of the University of Stuttgart in the fan or subscriber capacity or regular contributions. Finally, log data is gathered by Facebook even when the user reads the fanpage in a passive manner.
By means of its own use of Facebook, the University of Stuttgart is therefore increasing the quantity of data which is used and evaluated by Facebook Ireland Ltd.
2) Risk analysis:
By means of the extension of the distribution group and the increase in the connection options, the processing of the data by Facebook Ireland Ltd for other purposes and secret profile formation are encouraged. The openness for visitor contributions can lead to detrimental consequences for society, such as inappropriate or discriminatory comments or the distribution of sensitive data.
Should these consequences be shown to be significant when caused by Facebook Ireland Ltd, these are increased to a limited extent by the Facebook fanpage of the University of Stuttgart, as the data is already available to Facebook Ireland Ltd to a significant extent. In particular, the service provided by the University of Stuttgart does not lead to any obligation to set up a Facebook account, as enough other options for contacting the University of Stuttgart and obtaining information exist.
Also, the topics of science, teaching and research etc. very rarely lead to hate filled debates being triggered, which means that the likelihood of detrimental consequences is extremely limited.
3) Risk assessment
Overall, the additional risk caused by the Facebook fanpage of the University of Stuttgart is considered to be low to medium.
In addition, by using remedial measures, it is possible to further reduce the risk. However, the majority of these measures are the responsibility of the user: The user can protect himself or herself to a certain extent by means of various settings, for example by deleting his or her browser history, de-activating cookies or declining to provide location information when using photos. However, Facebook requires an official clear name, which is not the case with Twitter for example.
In addition, the continual editorial support is able to intervene in case of comments which are defamatory or insult other persons up to and including blocking the account.
4) Result
The use of Facebook by the University of Stuttgart is considered reasonable in light of the described risk and binding measures. The University of Stuttgart is obliged to observe future developments and regularly repeat and, where applicable, continually develop the assessment which has been carried out here.