Document Actions

You are here: FRIAS Privacy Policy Twitter


Information from the Freiburg Institute for Advanced Studies (FRIAS) on Twitter use


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 Twitter use.

1. General information about Twitter

 Twitter is a social network for short messages, photos, and videos. Registered users can publish short messages free of charge via this service. These tweets have a limited length and are usually visible to everyone.

Users can "follow" other users so that they can read their tweets in their own Twitter feed.

The advantages of Twitter are its wide reach and - in contrast to some other social networks - its readability without the need for the user to sign up, as well as its usability without the use of a clear name.

 More information about Twitter can be found here:

2. Purpose of the use of Twitter by the FRIAS

The Twitter channels are a useful addition to existing communication channels such as the website, press releases, newsletters, print products, and events. The Twitter channels primarily inform users about current press and public relations news as well as events and research projects based at FRIAS. In this way, the public can gain insight into the research projects at FRIAS.

For some target groups, the "classical" instruments alone (print, website, mailing) were no longer sufficient. Especially with regard to the target group of journalists and politicians, but also with regard to the scientific (research) community and students, we found out that we can reach them much more directly, faster and daily updated via Twitter, especially since interested recipients can subscribe to corresponding tweets. The Twitter channel enables a far-reaching distribution of our messages, better networking with other institutions and sources of information and an immediate reaction to the respective events.

In addition, we can obtain opinion leaders and feedback through direct dialogue with readers in order to optimize our scientific, organizational and communicative work.

3. Type and extent of Twitter use by FRIAS

The Twitter account of the FRIAS informs users about current press releases, events, news from science and research as well as events and other interesting facts about the institute. We do not use Twitter as a service or consulting channel.

Regular contents of the articles on @FRIAS_UFreiburg are

  • Press releases of the FRIAS
  • Announcements of selected events and dates organized by FRIAS
  • Interaction with journalists, researchers, companies and public authorities
  • Information on calls for tenders of the FRIAS
  • Presentation of current research projects of FRIAS
  • Latest news from the field of higher education policy
  • Selected press reports about FRIAS or individual FRIAS Fellows or staff members
  • Interaction with citizens, companies and public authorities

4. Responsibilities for editorial/technical support:

The responsibility for editorial support lies with the FRIAS press and public relations officer, .

5. Alternative information and contact possibilities:

Please note that the Twitter channel is only an additional option to get in contact with or receive information from FRIAS. Alternatively, the information offered via Twitter can also be accessed via the corresponding links on our website at or on the other linked websites.

You can always contact our central mailbox with all inquiries. Press inquiries can be sent to .

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 General Data Protection Regulation (GDPR), 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 Twitter 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 data protection declaration on Twitter), especially in view of the fact that its tweets are mainly a pure transmission of content without personal reference, and in the case of a reference to other Twitter users, only the data that they themselves have voluntarily provided (user's last name and tweets) is processed.

However, from the point of view of FRIAS, the use of Twitter in itself represents 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 Twitter) must be carried out.

By using a Twitter account, the respective user is subject to systematic monitoring by Twitter Inc. This may also reveal sensitive data such as political attitudes, sexual orientation or health problems, which can be linked and used to create a personality profile. Twitter users and thus affected persons can also be particularly worthy of protection, such as young people. Even if a user merely passively reads Twitter without having an account, sensitive data can be collected through the collection of log data, such as previously visited websites or the user's location data.

This is all the more true as Twitter Inc. cannot be verified or can only be verified to a limited extent. Since the data of users residing in Germany are not processed within Germany but in Ireland, 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 work and the provision of general information, it has a shared responsibility.

Joint responsibility does not mean that FRIAS confirms or guarantees that the products of Twitter Inc. comply with data protection regulations. Under the given circumstances it cannot do so. Co-responsibility rather means that FRIAS makes itself and others aware of the risks of social networks. Currently, social networks are in need of improvement in many aspects from a data protection perspective. Therefore, the Twitter users are shown an 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 users in the privacy policy of the FRIAS Twitter account.

FRIAS has committed itself to these measures in its usage concept. The advantages and disadvantages of Twitter use will be evaluated regularly in accordance with the terms of use of Twitter Inc. 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.

Twitter 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 Twitter use of FRIAS is as follows:

1. Risk identification:

The risks described at the beginning, which are associated with the use of Twitter, basically exist independently of FRIAS' own Twitter use. Also, in the vast majority of cases, the tweets of FRIAS itself do not refer to personal data, but rather disseminate their own, factual content.

Finally, the data processed through interaction with the FRIAS Twitter account - namely the tweets and/or the account name of a Twitter user - are already public/ generally access/ freely available on the internet.

However, by appearing on the Twitter page of FRIAS and the interrelationship they are made available to a broader/"more specific" public and thus may attract more attention and spread further than without this interaction. The fact that the FRIAS follows or is followed by other accounts also creates additional cross-connections and information about the respective Twitter user; for example, the interest in the FRIAS can be seen in the follower property or regular contributions. Finally, log data is also collected by Twitter when users passively read the page.

By using Twitter itself, FRIAS increases the amount of data that is used and evaluated by Twitter Inc.

2. Risk analysis:

By widening the distribution circle and increasing the possibilities for linking, the processing of data for other purposes by Twitter Inc. and clandestine profiling by Twitter Inc. is encouraged. Also, openness to visitor contributions can lead to adverse social consequences such as inappropriate or discriminatory comments or the dissemination of sensitive data.

While these damages may be substantial if caused by Twitter Inc. itself, the Twitter profile of FRIAS only increases these damages to a very limited extent. This is because the data is already available for Twitter Inc. to a large extent. Especially the offer of FRIAS does not force you to create a Twitter account, as there are enough alternative contact and information possibilities to FRIAS.

Also, the topics of science, teaching, research etc. are only suitable to a limited extent to trigger hateful debates, so that the probability of damage occurring is very limited.

3. Risk assessment

Overall, the additional risk caused by FRIAS' Twitter account can therefore be classified as low to medium.

Moreover, it is possible to implement remedial measures that further reduce the risk. A large part of these measures is the responsibility of the users: For example, there is no obligation to use a clear name when using Twitter. In addition, users can protect themselves to a certain extent by various settings, such as deleting their browser history, deactivating cookies, or not sharing their location when using photos.

In addition, the continuous editorial support allows for intervention in case of comments that violate the user's honour or personality, up to the blocking of the account. The FRIAS has formulated a netiquette for the use of its social media offers, which the institute will ensure is observed in the maintenance of the site.

4. Result

The use of Twitter by 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 technical platform and services of Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103 U.S.A. for the short news service offered here:

Responsible for the data processing of persons living outside the United States is Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland.

Please note that you use the Twitter short message service offered here and its functions on your own responsibility. This applies in particular to the use of the interactive functions (e.g. share, rate). Alternatively, you can also access the information offered via this page on our website at

1. Data processed by Twitter:

For information on what data is processed by Twitter and for what purposes it is used, please refer to the Twitter privacy policy:

Twitter Inc. is committed to the principles of the EU-US Privacy Shield. You can find more information on this at:

FRIAS has no influence on the type and scope of the data processed by Twitter, the type of processing and use or the transfer of this data to third parties. It also has no effective means of control in this respect.

By using Twitter, your personal data will be collected, transmitted, stored, disclosed and used by Twitter Inc. and in the process will be transferred, stored and used in the United States, Ireland and any other country where Twitter Inc. does business, regardless of your residence.

Twitter processes the data you voluntarily enter such as your name and user name, email address, telephone number or the contacts in your address book when you upload or synchronize it.

On the other hand, Twitter also evaluates the content you share to determine what topics you are interested in, stores and processes confidential messages that you send directly to other users, and can determine your location using GPS data, wireless network information or your IP address to send you advertising or other content.

Twitter Inc. may use analytics tools such as Twitter or Google Analytics for evaluation purposes. FRIAS has no influence on the use of such tools by Twitter Inc. and has not been informed about such potential use. Should tools of this kind be used by Twitter Inc. for the account of FRIAS, FRIAS has neither commissioned nor approved nor supported this in any other way. Nor will it be provided with the data obtained during the analysis. Only certain non-personal information about the tweet activity, such as the number of profile or link clicks through a certain tweet, can be viewed by FRIAS via your account. Furthermore, FRIAS has no possibility to prevent or disable the use of such tools on your Twitter account.

Finally, Twitter also receives information when you view content, for example, even if you have not created an account. This so-called "log data" may include your IP address, browser type, operating system, information about websites you visit, your location, your mobile phone provider, the device you use (including device ID and application ID), the search terms you use and cookie information.

Twitter buttons or widgets embedded in websites and the use of cookies enable Twitter to track your visits to these websites and assign them to your Twitter profile. This data can be used to offer content or advertising tailored to you. Accordingly, FRIAS does not use such buttons and widgets on its own websites.

Even if Twitter Inc. is a non-European provider with a European branch only in Ireland, it is bound by the GDPR. This concerns, for example, your rights to information, blocking or deletion of data.

You can limit the processing of your data in the general settings of your Twitter account and under "Privacy and security". In addition, you can restrict Twitter access to contact and calendar data, photos, location data, etc. on mobile devices (smartphones, tablet computers) in the settings there. However, this is dependent on the operating system used.

Further information on these points is available on the following Twitter support pages: and

You can find out about the possibility of viewing your own data on Twitter here:

Information about the conclusions drawn from Twitter to you can be found here:

Information about the available personalisation and data protection settings can be found here (with further references):

You can also request information via the Twitter privacy form or archive requirements: and

2. Data processed by FRIAS:

FRIAS also processes your data. It does not collect any data itself via its Twitter account. However, the data entered by you on Twitter, in particular, your user name and the content published under your account, will be processed by us to the extent that we re-tweet or reply to your tweets, if applicable, or even write tweets from us that refer to your account. The data you freely publish and distribute on Twitter will be included by FRIAS in its offer and made available to its followers.

3. Rights, documentation, evaluation:

If you have any questions regarding our information offer you can contact us at . You can assert your rights to information, blocking or deletion of data with our data protection officer: .

This data protection declaration can be found here in the currently valid 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: Twitter 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 on Twitter and other social networks and how you can protect your data can also be found at




Networking and communication with other Twitter users

Subscribing to other Twitter users or tweeting by the Freiburg Institute for Advanced Studies (FRIAS) does not imply any statement about the relationship between FRIAS and these users or the content published by them. In particular, it does not imply approval or recommendation for its followers. FRIAS regards the subscription of other users or tweets as a way of networking with other organs, persons and institutions for the fast dissemination and knowledge of information related to science.

This also means that FRIAS will not automatically subscribe to all its followers. The non-subscription of a user by FRIAS does not have any meaning, especially it does not mean that FRIAS rejects or disinterests the user.

Way and purpose of use

FRIAS uses its account mainly for its own tweets and retweets within the framework of the way it describes in its usage concept. In selected cases, it will also communicate via direct messages and reply to retweets and comments as far as the exchange of information on topics related to FRIAS is concerned. For all kinds of inquiries, contact possibilities outside of Twitter are available, such as emails to . There will be no detailed consultation, but a website link will refer to the corresponding telephone and e-mail contacts of FRIAS.

Twitter and data protection

The use of Twitter by FRIAS does not imply any endorsement of this medium or the company or the privacy policy of Twitter Inc. FRIAS recommends all users to inform themselves about the processing of their data by Twitter and to protect their privacy as much as possible: This includes reading the privacy policy of Twitter Inc. Important aspects are also summarized in the FRIAS' own privacy policy on Twitter use.

In addition, every user should at least make the following privacy settings:

Open a user account only with the absolutely necessary data, preferably using a pseudonym

  • Disabling the widget function
  • Prevention of cross-site tracking (for example, by using the Ghostery AddOn in the browser)

Status: January 2020



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 .

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:

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