Structure
Usage concept
The Freiburg Institute for Advanced Studies (FRIAS) is the University of Freiburg’s international research college. It was established after Freiburg’s success in the Federal Excellence Initiative in October 2007. As a centre-piece of the Albert-Ludwigs-University’s institutional strategy, FRIAS pursues three main objectives: to promote top-level research, to develop new interdisciplinary areas of competence and knowledge, and to foster the advancement of outstanding junior scholars.
The public relations work for FRIAS also takes place on Twitter. With the present usage concept, FRIAS, as a public body, assumes its responsibility and exemplary function for the use of social media in accordance with the "Guidelines of the State Commissioner for Data Protection and Freedom of Information (LfDI) for the use of social networks by public authorities". Please also note our data protection statement and assessment of the consequences of LinkedInuse.
1. General information about LinkedIn
LinkedIn, based in Mountain View/USA, is a social career network for maintaining existing business contacts and for establishing and linking new business relationships. With over 350 million users, LinkedIn is currently the largest online career network in the world. It is international and especially widespread in the English-speaking world. This gives LinkedIn a large international reach compared to other career networks, such as Xing, which is mainly distributed in German-speaking countries. There is a free basic version, optionally premium services with additional functions can be booked.
LinkedIn is primarily aimed at managers and specialists as well as people interested in careers in general. The network enables its users to communicate and exchange information directly with people who have the same professional interests. In addition, the network serves the recruitment of personnel; users present themselves as qualified employees, companies and organisations as attractive employers. Although the focus of LinkedIn is typically on the professional sector, many users also use the network to link private contacts.
On LinkedIn you can create personal profiles or company pages, whereas company pages can only be created by a personal profile with administrator rights, there is no clear name policy. To use the network functions you have to be registered as user_in. Some content released by the LinkedIn user can be read without the need for a separate login.
On LinkedIn, contributions can be provided in the form of texts, photos, videos and live streams. Registered users can use this service to publish their content free of charge, network with other users or company sites, comment on their contributions, mark them with "Like" or "Don't like it anymore", and share them. Users can recommend or subscribe to company sites, so that relevant articles are displayed in their own LinkedIn feed.
More information about LinkedIn can be found here: https://www.linkedin.com/help/linkedin.
2. Purpose of the use of LinkedIn by the FRIAS
The LinkedIn company website of the Freiburg Institute for Advanced Studies (FRIAS) is a useful addition to the existing communication channels, such as the website, press releases, newsletters, print products and events.
Social career networks are becoming increasingly important for success on the international job market. Especially with regard to our target groups alumni and alumnae and their (potential) employers, but also for those interested in further education, our own internationally operating employees and potential employees, LinkedIn offers the advantage that we can reach them much more directly and quickly, especially since interested users can simply subscribe to the company website. The LinkedIn presence of FRIAS thus enables a far-reaching distribution of articles and impressions of FRIAS and the observation of the reactions immediately following.
LinkedIn can facilitate the communication of the FRIAS because the target groups can easily and uncomplicatedly contact the FRIAS with questions, suggestions or even criticism. In this way LinkedIn enables fast and uncomplicated communication at eye level and can thus convey an informative and inviting picture of the institute with its offers, qualities and goals.
With the help of the LinkedIn company website, the LinkedIn public can gain insight into the activities and research of FRIAS. It also supports the activities of the internationally networked and active staff members within their individual networks with, for example, international project partners. This supports FRIAS Freiburg in its efforts to further internationalize its funding programs.
3. Type and extent of Twitter use by FRIAS
The FRIAS operates a company website on LinkedIn in the LinkedIn basic version with logo and short profile.
The LinkedIn company page of FRIAS informs users about current reporting on university topics, news from science, research and teaching as well as current job offers. We do not use LinkedIn as a consulting channel. Inquiries that reach us via the comment function are forwarded directly to the responsible office and referred to communication channels such as telephone and e-mail.
Regular contents of the articles on the LinkedIn company page of FRIAS are
- Selected news
- Vacancies and Call for Applications
- Selected press articles
4. Responsibilities for editorial/technical support:
The responsibility for editorial support lies with the FRIAS press and public relations officer, presse@frias.uni-freiburg.de.
5. Alternative information and contact possibilities:
Please note that the LinkedIn channel is only an additional option to get in contact with or receive information from FRIAS. Alternatively, the information offered via LinkedIn can also be accessed via the corresponding links on our website at www.frias.uni-freiburg.de or on the other linked websites.
You can always contact our central mailbox info@frias.uni-freiburg.de with all inquiries. Press inquiries can be sent to presse@frias.uni-freiburg.de.
Visiting address & postal address:
Freiburg Institute for Advanced Studies (FRIAS)
Albert Street 10
79098 Freiburg
6. Voluntary commitment
This utilization concept is evaluated by us once a year with regard to whether and how it is used. This evaluation of the utilisation concept takes into account the utilisation figures and ranges as well as the target group structure of the networks.
Status: January 2020
Impact assessment
According to the general rule of Article 35(1) of the European Data Protection Regulation (EDPS), a data protection impact assessment shall be carried out where a form of processing is likely to present a high risk to the rights and freedoms of natural persons by reason of the nature, scale, circumstances and purposes of the processing, in particular where new technologies are used. The "Guideline of the State Commissioner for Data Protection and Freedom of Information (LfDI) on the Use of Social Networks by Public Authorities" makes the assessment of the consequences of the planned processing operations for the protection of personal data within the meaning of the DSGVO mandatory.
The LinkedIn offer of the Freiburg Institute for Advanced Studies (FRIAS) itself does not trigger this consequence due to the very limited scope of its own data processing (see the LinkedIn data protection declaration), especially in view of the fact that its tweets are mainly a pure sending of content without personal reference, and in the case of a reference to other LinkedIn users, only the data that they themselves have voluntarily provided (user name and tweets) is processed.
However, from the point of view of FRIAS, the use of LinkedIn is in itself a high-risk processing due to its far-reaching effects with regard to the evaluation of the data by Twitter Inc. for advertising purposes, for which a data protection impact assessment (by LinkedIn) must be carried out.
By using a LinkedIn account, the respective user is subject to systematic monitoring by LinkedIn. This can also reveal sensitive data such as political attitudes, sexual orientation or health problems, which can be linked and used to create a personality profile. Also, particularly vulnerable persons such as young people can be LinkedIn users and thus affected persons. Even if you just passively read LinkedIn without having an account, sensitive data can be collected through the collection of log data, such as previously visited websites or location data of the user.
This is all the more true because LinkedIn. cannot be checked or can only be checked to a limited extent. Since the data of users residing in Germany are not processed within Germany but in non-European countries, there are higher hurdles for access to (judicial) legal protection than with a company residing in Germany.
In this respect, FRIAS assumes that as a public body that uses a social network for public relations and the provision of general information, it shares responsibility.
Joint responsibility does not mean that FRIAS confirms or guarantees the data protection conformity of LinkedIn products. Under the given circumstances it cannot do so. Rather, joint responsibility means that FRIAS makes itself and others aware of the risks of social networks. Currently, social networks are in need of improvement in many points from a data protection perspective. For this reason, LinkedIn users are shown alternative, more data protection-friendly communication channels by links to the FRIAS homepage.
The risks generally associated with the use of social media are also pointed out to the users in the privacy policy of the LinkedIn account of the FRIAS.
FRIAS has committed itself to these measures in its usage concept. Advantages and disadvantages of LinkedIn use will then be evaluated on a regular basis in accordance with the LinkedIn terms of use. This evaluation of the usage concept takes place annually and takes into account the usage figures and reach as well as the target group structure and usage behaviour of the networks.
LinkedIn usage is thus embedded in a package of measures (usage concept, privacy policy, disclaimer and netiquette). Against this background, the assessment of the consequences of LinkedIn use of the FRIAS is as follows:
1. Risk identification:
The risks described at the beginning, which are associated with the use of LinkedIn, exist in principle independently of FRIAS' own Twitter LinkedIn. Also, in the vast majority of cases, FRIAS itself does not refer to personal data, but disseminates its own, factual content.
Finally, the data processed through interaction with the LinkedIn account of FRIAS - namely the contributions and/or the account name of a LinkedIn user - are already public/ generally accessible/ freely available on the internet.
However, by appearing on the LinkedIn page of the FRIAS and the interrelationship, they are made available to a broader/"more specific" public and thus may achieve greater attention and wider distribution than without this interaction. The fact that the FRIAS follows other accounts or that they follow it also creates additional cross-connections and information about the respective LinkedIn user; for example, the interest in the FRIAS can be seen in the subscriber/follower characteristic or regular contributions. Finally, LinkedIn also collects log data when users passively read the page.
By using LinkedIn itself, FRIAS increases the amount of data that is used and evaluated by LinkedIn.
2. Risk analysis:
Overall, the additional risk caused by the LinkedIn account of FRIAS can therefore be classified as low to medium.
In addition, it is possible to implement remedial measures that further reduce the risk. A large part of these measures is the responsibility of the users: There is no obligation to use a clear name when using LinkedIn. In addition, users can protect themselves to a certain extent by various settings, such as deleting their browser history, deactivating cookies, or not allowing the use of photos.
With regard to particularly worthy of protection, such as young people, it can be seen that they usually do not belong to the LinkedIn target group. Although registration with LinkedIn is possible from the age of 16, LinkedIn as a career network is mainly aimed at professionals and managers who want to network with each other worldwide on their own initiative.
This target group is usually significantly older and has the appropriate training and must therefore weigh up the professional benefits of the service against the protection of their data. Nevertheless, it should be emphasized that especially in business networks there is an increased risk of fake profiles and identity theft, as the business/professional environment of LinkedIn users is often described in detail.
In addition, some LinkedIn practices, such as pretending to be a member of existing contacts of LinkedIn users and independently sending out email invitations to join LinkedIn, can cause suspicion among LinkedIn users' acquaintances or even damage their professional reputation.
LinkedIn users should therefore be especially advised to prohibit LinkedIn from accessing address books and other external services and to deactivate the automatic sending of email invitations, since LinkedIn also contacts contacts outside its own network and stores their data. For additional security, you may suggest that users use LinkedIn only from their desktop in their browser and not to install LinkedIn apps on their smartphones / mobile devices.
As a further remedial measure, the continuous editorial support allows for intervention in case of comments that violate honour or personality up to the blocking of the account. The University of Freiburg has formulated a netiquette for the use of its services, which it will ensure is adhered to when maintaining the site.
4. Result
The use of LinkedInby FRIAS is justifiable in view of the risks described above and the binding measures that are planned. FRIAS undertakes to monitor further developments and to regularly repeat and, if necessary, further develop the audit carried out here.
Status: January 2020
Privacy policy
The Freiburg Institute for Advanced Studies (FRIAS) uses the information service offered on LinkedIn via the technical platform and services of LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA: https://www.linkedin.com/company/albert-ludwigs-universit-t-freiburg-im-breisgau.
Responsible for the data processing of persons living in the designated countries of the DSGVO (European Union (EU), European Economic Area (EEA) and Switzerland) is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.
We would like to point out that you use the LinkedIn site offered here and its functions on your own responsibility. This applies in particular to the use of the interactive functions (e.g. commenting, sharing, rating).
The information and publications found on our LinkedIn page are a voluntary additional offer. Visiting our LinkedIn page is only possible for registered users of the LinkedIn platform. Alternatively, you can access all information offered on this page on our website at www.frias.uni-freiburg.de.
1. Data processed by Twitter:
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For information about what data is processed by LinkedIn and for what purposes, please refer to the LinkedIn Privacy Policy: https://www.linkedin.com/legal/privacy-policy.
LinkedIn Corporation and its US subsidiaries ("LinkedIn") are committed to the principles of the EU-US Privacy Shield with respect to the collection, use and storage of personal data provided to LinkedIn by LinkedIn users from the countries designated by the DSGVO.
More information is available at https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0 and https://www.linkedin.com/help/linkedin/answer/62533?trk=microsites-frontend_legal_privacy-policy&lang=de.
The FRIAS has no control over the nature and extent of the data processed by LinkedIn, the manner in which this data is processed and used, or the disclosure of this data to third parties. It also has no effective means of control in this respect. Similarly, FRIAS has no knowledge of the content of the data you provide to LinkedIn and cannot provide information about what data is stored about you when you use the LinkedIn service.
When you use LinkedIn, your personal data is collected, transferred, stored, disclosed and used by LinkedIn Corporation. LinkedIn transfers your data from the countries designated in the DSGVO to the United States of America (USA) and back. LinkedIn data centres for the storage of its members' information are currently located in the United States and Singapore.
LinkedIn collects and processes not only your voluntarily entered data such as profile, registration, contact and calendar data, but also, for example, location and device information as well as Internet Protocol addresses (IP addresses). LinkedIn may also use cookies or similar technologies to identify you outside its own services and across various devices.
LinkedIn collects and analyzes data from the content you publish and upload, news and messages, as well as data from partners and affiliates, such as information provided by your workplace/educational institution, third-party websites or services.
For more information, please visit: https://www.linkedin.com/legal/privacy-policy.
LinkedIn may use your personal information to provide you with other services (including advertisements), including automated systems and proprietary reasoning, and to customize them to be more relevant and useful to you and others.
LinkedIn may also aggregate information internally about various services covered by its privacy policy (for details, see https://www.linkedin.com/legal/privacy-policy#use).
LinkedIn does not disclose how LinkedIn uses information from visits to LinkedIn sites for its own purposes, the extent to which activities on the LinkedIn site are attributed to individual users, how long LinkedIn stores this information, and whether information from a visit to the LinkedIn site is shared with third parties.
Furthermore, LinkedIn may provide third parties (partner companies and external service providers) to use LinkedIn's services in order to assist them in providing their services (e.g. maintenance, analysis, testing, payment, fraud detection, marketing and development).
These third parties will have access to your information to the extent reasonably necessary to perform the relevant tasks for LinkedIn, and are required not to disclose or use your information for any other purpose. For more information, please visit https://www.linkedin.com/legal/privacy-policy#share.
If third party services are used by LinkedIn for the LinkedIn site of the FRIAS, the University of Fribourg has not commissioned, approved or otherwise supported this in any way. Neither is it provided with the personal data obtained during the analysis. Only certain, non-personal, aggregated information about the activity, such as the number of profile or link clicks on a particular posting or page, can be viewed by FRIAS through its account. Furthermore, FRIAS has no way of preventing or stopping the use of such services on its LinkedIn page.
Finally, LinkedIn also receives information when you view content, for example, even if you have not created an account (for example, via a LinkedIn public profile). This so-called "log data" may include your IP address, browser type, operating system, information about the website and pages you previously visited, your location, your mobile operator, the device you are using (including device ID and application ID), the search terms you used, and cookie information.
LinkedIn may use LinkedIn buttons or widgets embedded in web pages and the use of cookies to track your visits to these web pages and to associate them with your LinkedIn profile. This information can be used to provide content or advertising tailored to you.
Accordingly, FRIAS does not use such buttons and widgets on its own websites. Even if LinkedIn Corporation is a non-European provider, it is bound by the DSGVO in the designated countries. This concerns for example your rights to information, blocking or deletion of data.
You have the possibility to limit the processing and visibility of your data in your account navigation under "Settings and Privacy" in the various menu items listed there.
Please also note that all information you enter in your profile is publicly visible by default, i.e. members who log in to the network and customers of LinkedIn services can view it. This also applies to your activities within the service, such as comments on posts, "Like" marks or the "Follow" function. Group memberships are also publicly visible.
If you share posts, the default setting is that this is done publicly. In the options you can limit the visibility of these posts to your contacts. In LinkedIn you can also specify in the settings if you want to share your contact list with all your contacts. With a so-called public profile, your content can be found outside LinkedIn and in search engines.
More information on these points is available on the following LinkedIn help pages: https://www.linkedin.com/help/linkedin .
You can view and download your own data on LinkedIn in your account navigation under "Settings and privacy" in the "Privacy" tab under "How LinkedIn uses your data" or at https://www.linkedin.com/psettings/member-data .
For information about LinkedIn's extensive data collection and other privacy settings, please visit: http://www.linkedin.com/legal/privacy-policy .
The ability to opt-out of interest-based advertising (not advertising in general) can be found at https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out .
You may also contact LinkedIn via the LinkedIn contact form or via the LinkedIn office in Ireland responsible for the Designated Countries for questions regarding the Privacy Policy or User Agreement:
Online contact form: https://www.linkedin.com/help/linkedin/ask/PPQ .
postal address:
LinkedIn Ireland Unlimited Company
Attn: Legal Dept. (Privacy Policy and User Agreement)
Wilton Plaza
Wilton Place, Dublin 2
Ireland
You may request LinkedIn to delete a portion of your personal information (for example, if the provision of services to you is no longer necessary) through the contact methods listed above.
However, there are also uses of data that you cannot influence via the settings.
If you do not agree with such use, the only option is to close your account: https://www.linkedin.com/psettings/account-management/close-submit .
If you are resident in one of the designated countries of the DSGVO, you also have the right to lodge a complaint with the Irish data protection commissioner: https://www.dataprotection.ie/docs/Contact-us/b/11.html .
2. Data processed by FRIAS:
FRIAS also processes your data. It does not collect any data about your LinkedIn account. However, the data you enter into LinkedIn, in particular your user name and the content published under your account, is processed by us to the extent that we may share or comment on your postings, or even write postings from us that refer to your account. The data you freely publish and distribute on LinkedIn will be included by FRIAS in its offer and made available to its fans and subscribers.
3. Rights, documentation, evaluation:
If you have questions about our information offer, you can contact us at presse@frias.uni-freiburg.de. You can assert your rights to information, blocking or deletion of data with our data protection officer: datenschutzbeauftragter@uni-freiburg.de .
This data protection declaration can be found here in its current version. In the event of changes to the data protection declaration, you will find links to the previous versions.
You will find the concept underlying the offer under the corresponding menu item: LinkedIn usage concept. This usage concept is evaluated by us once a year with regard to whether and how it is used. This evaluation of the usage concept takes into account the usage figures and reach as well as the target group structure of the networks.
Further information about LinkedIn and other social networks and how you can protect your data can also be found at www.youngdata.de .
Status: January 2020
Disclaimer
Networking and communication with other LinkedIn users
Subscribing or likening other LinkedIn profiles or likening postings or comments by the Frias Institute for Advanced Studies (FRIAS) does not imply any statement about the relationship of FRIAS to these profiles or the content published by them. In particular, it does not imply any approval or recommendation for their subscribers. Rather, the FRIAS considers the subscription to other profiles or the likening of posts and comments as a way of networking with other bodies, persons and institutions for the rapid dissemination and knowledge of information related to topics relevant to FRIAS.
The FRIAS will not subscribe to all its subscribers. Not subscribing to a profile by the FRIAS does not have any meaningfulness either. In particular, it does not mean that the FRIAS rejects or is disinterested in the respective profile.
Way and purpose of use
The FRIAS uses its LinkedIn profile for its own postings within the framework of the way it is described in its usage concept. It will also respond to comments if necessary, as far as the exchange of information on topics related to the Institute is concerned. For all kinds of inquiries, contact possibilities outside of LinkedIn are available, such as e-mails to: presse@frias.uni-freiburg.de . There will be no detailed consultation, but rather a website link to the corresponding telephone and e-mail contacts of FRIAS.
Twitter and data protection
FRIAS' use of LinkedIn does not imply endorsement of that medium or company or LinkedIn's privacy policy. FRIAS recommends all users to inform themselves about the processing of their data by LinkedIn and to protect their privacy as much as possible: This includes reading LinkedIn's privacy policy. Important aspects are also summarized in the FRIAS' own privacy policy on LinkedIn use.
In addition, every user should at least make the following privacy settings:
Opening a user account only with the absolutely necessary data
Disabling the widget function
Prevention of cross-site tracking (for example, by using the Ghostery AddOn in the browser)
Status: January 2020
Netiquette
1. On this social media site, we do not tolerate any offensive or illegal contributions. In particular, please refrain from doing so:
1.1. threats, bullying, harassment, insults, degradations, slander, insinuations, slander, libel and hate speech in any form
1.2. posts with attitudes/viewpoints that are xenophobic, sexist, or discriminatory towards minorities, communities or individuals
1.3. posts which explicitly represent party political, religious and/or ideological contents and aims
1.4. endorse, trigger or glorify violence, war, discrimination, unconstitutional or anti-democratic acts
1.5. pornographic or sadistic representations.
2. Do not post any advertising or spam.
2.1 Any commercial content will be removed by us immediately.
2.2 It is also not allowed to use the social networks to send advertising or other marketing content to others via private messages (spam).
3. Respect privacy and anonymity! Please help us to ensure the privacy and rights of other users. Do not give personal/private details of other people, whether they are also users of the network or not. This primarily includes name, address and other personal data, but also photos/videos. Remember that a subsequent, complete, deletion may be difficult.
4. As a user of the site, respect the copyright and intellectual property rights! In particular, make sure that you have the right to distribute the content, photos, works of art or other works on this social media site that are protected by copyright, trademark or name. By posting certain content, you confirm that you have the necessary permission to do so. In addition, you consent to the further use of such content on the various social media pages of the Freiburg Institute for Advanced Studies (FRIAS).
5. "Careful what you say!" There is nothing to be said against being informal and using dialect or colloquial language, but no offensive language, swear words or the like will be tolerated. Nor are sexist remarks tolerated. Remain friendly and tolerant! Even if you feel attacked or offended by a mail/comment, remain objective and fair. If you feel that you are not being treated properly, you are welcome to inform us. The easiest way to do this is to send a direct message to the site administrator or to send a mail to the press and public relations officer at presse@frias.uni-freiburg.de.
6. To make the exchange accessible and understandable for everyone, please post only in German or English.
7. The comments, opinions, and links of users posted on the social media sites operated on behalf of FRIAS do not necessarily reflect the opinion of FRIAS. Furthermore, copyrighted works or trademarks of the FRIAS may not be used without prior written consent of the Institute.
8. All posts must have a concrete, direct reference to the activities of the FRIAS and comments must refer to the commented post. In case of doubt, the respective site administrator should be contacted before posting.
9. Posts/content that violates the principles formulated here will be removed immediately. The author will be informed and admonished.
10. Users who ignore the netiquette of our social media pages despite repeated warnings will be excluded from using our social media pages. Depending on the type of content and/or the intensity of the insult, discrimination, threat, etc., we reserve the right to report this incident and the user to the respective site provider. These all have their own community standards, which also form the basis of our netiquette. As an example we refer to the Community Standards of Facebook: https://www.facebook.com/communitystandards/
11. it is not possible for us to check all postings of our users immediately. The site administrators cannot therefore be held responsible or liable for the content of the comments. Rather, each user is responsible for his or her contributions. We would like to point out that comments which violate applicable law are also subject to prosecution on the internet and can be reported to the police by FRIAS or by users.
Status: January 2020
