According to the general rule of Article 35 (1) of the European Data Protection Regulation (GDPR), a data protection impact assessment must be carried out when a form of processing, in particular when using new technologies, is likely to result in a high risk to the rights and freedoms of natural persons by virtue of the nature, scope, context and purposes of the processing. The "Framework for Action on the Use of 'Social Media' by Public Authorities" of the State Commissioner for Data Protection and Freedom of Information  Rhineland-Palatinate (LfDI) also makes it mandatory to assess the consequences of the intended processing operations for the protection of personal data within the meaning of the GDPR.

The YouTube offering of HWG LU itself does not trigger this consequence due to the only very small scope of its own data processing (see the privacy policy on YouTube). However, YouTube videos often have a direct personal reference. When posting its own content, HWG LU therefore ensures that the copyrights to the image material and the image rights of any persons depicted are taken into account.

In the view of HWG LU, the YouTube use in itself represents a processing with a high risk due to its far-reaching effects, in particular with regard to the evaluation of the data by YouTube LLC or Google LLC for advertising purposes and the like, for which a data protection impact assessment must be carried out.

By using a YouTube account, the respective user places himself or herself under systematic observation by YouTube LLC. This can also reveal sensitive data such as political attitudes, sexual orientation or health problems, which can be linked together and used to create a personality profile. People who are particularly worthy of protection, such as young people, can also be YouTube users and thus data subjects. Even in the case of merely passive use of YouTube content without 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 YouTube LLC cannot be audited or can only be audited to a limited extent. Since the data of German users may be processed outside of Germany, there are higher hurdles for access to (judicial) legal protection than with a company based in Germany.

In this respect, HWG LU assumes that it bears joint responsibility as a public body that uses a social network for public relations work and to provide general information.

Co-responsibility does not mean that HWG LU confirms or guarantees the data protection conformity of YouTube LLC's products. It cannot do so under the given circumstances. Rather, co-responsibility means that HWG LU 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. For this reason, YouTube users are shown alternative, more data protection-friendly communication channels by means of links to the HWG LU homepage.

Users are also made aware of the risks generally associated with the use of social media in the privacy policy of the HWG LU YouTube channel.

HWG LU has committed itself to these measures in its usage concept . Advantages and disadvantages of YouTube use are evaluated regularly in accordance with the terms of use of YouTube LLC. This evaluation of the usage concept is carried out regularly and takes into account usage figures and reach as well as the target group structure and usage behavior of the networks.

YouTube 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 YouTube use by HWG LU is as follows:

1. risk identification:

The risks described at the beginning that are associated with YouTube use exist in principle independently of HWG LU's own YouTube use. Also, in the vast majority of cases, HWG LU's own video contributions do not relate to sensitive personal data, but rather disseminate their own factual content.

Finally, the data processed through interaction with the YouTube account of HWG LU or other accounts - namely the videos or/and the account name of the YouTuber* - are already publicly/generally accessible/free on the Internet.

However, by appearing on HWG LU's YouTube page and interacting, they are made available to a broader/more "specific" public and may thus achieve greater attention and wider distribution than without this interaction.

Also, by HWG LU following or being followed by other YouTube channels, additional cross-relationships and information about the particular YouTube user or users are created; for example, interest in research topics can be gauged by subscription status or regular posts.

Finally, log data is also collected by YouTube during passive use of the site.

Thus, by its own YouTube usage, HWG LU increases the amount of data that is used and analyzed by YouTube LLC or Google LLC.

2. risk analysis:

By expanding the distribution circle and increasing the linking possibilities, the processing of data for other purposes by YouTube LLC or Google LLC and surreptitious profiling is favored. Also, openness to visitor submissions may lead to adverse social consequences such as inappropriate or discriminatory comments or the dissemination of sensitive data.

While these harms may present themselves as material if caused by YouTube LLC or Google LLC itself, they are increased to a limited extent by HWG LU's YouTube channel. This is because the account data of the respective user is to a significant extent available to YouTube LLC anyway. In particular, the offer of HWG LU does not create a compulsion to create a YouTube account, as there are sufficient alternative contact and information options for HWG LU.

Also, the topics of research and study are only suitable to a limited extent to trigger hateful debates, so that also in this respect the probability of occurrence of damage is only very limited.

3. risk assessment

Overall, the additional risk caused by the YouTube account of HWG LU is therefore to be classified as low to medium.

In addition, it is possible to implement remedial measures that further reduce the risk. These include, for example, HWG LU's influence on the providers. However, a large part of these measures are the responsibility of the user: For example, there is no obligation to use a clear name when using YouTube. In addition, the user can protect himself or herself to a certain extent through various settings, such as deleting the browser history and deactivating cookies.

In addition, continuous editorial support makes it possible to intervene in the event of comments that are defamatory or violate personal rights, up to and including blocking the account. HWG LU has formulated a netiquette for the use of its offer, which it ensures is observed when managing the site.

4. result

YouTube use by HWG LU is justifiable in view of the risks described and binding measures provided. HWG LU undertakes to monitor further developments and to regularly repeat and, if necessary, further develop the review carried out here.

Status: December 2022

For the video platform offered here, HWG LU uses the technical platform and services of YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066, USA: https://www.youtube.com/user/HSLudwigshafen.

The authorized service provider for YouTube LLC within the meaning of Section 5 (1) of the NetzDG in Germany is Google Germany GmbH, - Legal Department -, ABC-Straße 19, 20354 Hamburg, Germany.

We would like to point out that you use the YouTube platform offered here and its functions on your own responsibility. This applies in particular to the use of the interactive functions (for example, sharing, rating, commenting, embedding). Alternatively, you can also access the study or work-related information offered via this page on our website at www.hwg-lu.de .

1. data processed by YouTube:

Information on what data is processed by YouTube and for what purposes can be found in YouTube's privacy policy: https://policies.google.com/privacy?hl=en.

HWG LU has no influence on the scope of the data processed by YouTube, the way it is processed and used, or the transfer of this data to third parties. Nor does it have any effective means of control in this respect.

By using YouTube, your personal data is collected, transferred, stored, disclosed and used by YouTube LLC and thereby transferred to, stored in and used in the United States and any other country in which YouTube LLC does business, regardless of your residence.

YouTube processes on the one hand your voluntarily entered data such as name and user name, e-mail address and telephone number.

On the other hand, YouTube 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, information about wireless networks or your IP address in order to send you advertising or other content.

For analysis, YouTube LLC may use analytics tools such as Google Analytics. HWG LU has no influence on the use of such tools by YouTube LLC and has not been informed about such potential use. If tools of this type are used by YouTube for the account of HWG LU, HWG LU has neither commissioned nor approved this nor supported it in any other way. Also, the data obtained to it during the analysis will not be made available. Only certain non-personal information about YouTube activity, such as the reach of a video, can be viewed by HWG LU via its account. Moreover, HWG LU has no way to prevent or turn off the use of such tools on its YouTube account.

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

Via YouTube buttons or widgets embedded in websites and the use of cookies, it is possible for YouTube to record your visits to these websites and, if applicable, to assign them to your YouTube profile. Based on this data, content or advertising can be tailored to you. Accordingly, HWG LU refrains from using such buttons and widgets on its own websites.

As YouTube LLC. is a non-European provider, it is not bound by German data protection regulations according to its own interpretation. This concerns, for example, your rights to information, blocking or deletion of data or the possibility to object to the use of usage data for advertising purposes.

You have options to restrict the processing of your data in the general settings under the item "History and data protection". In addition, you can restrict YouTube's access to contact and calendar data, photos, location data, etc. on mobile devices (smartphones, tablet computers) in the settings options there. However, this depends on the operating system used.

Further information on these points is available on the following YouTube support page: https://policies.google.com/privacy?hl=de#infochoices°.

Information about the inferences drawn or data collected about you by YouTube or Google can be found here: https://myactivity.google.com/?utm_source=my-account&utm_medium=&utm_campaign=my-acct-promo.

Information on the available personalization and data protection setting options can be found here (with further references): https://policies.google.com/privacy?hl=de#infochoices°.

Furthermore, you have the option to query the information stored about you by Google services such as YouTube: https://support.google.com/accounts/answer/162744?hl=de.

2. Data processed by HWG LU:

HWG LU also processes your data. While it does not itself collect any data about your YouTube account or your YouTube usage behavior. However, the data you enter on YouTube, in particular your username and the content published under your account, is processed by us to the extent that we may share your videos on our own channel after consultation. This may be the case, for example, if you are a scientist or employee at HWG LU or at external scientific institutions and have produced a thematically relevant video as part of your work. The data you may have published and distributed on YouTube will thus be included by HWG LU in its offer and made available to its subscribers.

3. rights, documentation:

If you have any questions about our information offering, you can contact us at info@ 8< SPAM protection, please remove >8 hwg-lu.de . You can assert your rights to information, blocking or deletion of data with our/our data protection officer: datenschutz@ 8< SPAM protection, please remove >8 hwg-lu.de.

You can find the current version of this data protection declaration here. In the event of changes to the data protection declaration, you will find the previous versions linked.

The concept underlying the offer can be found under the corresponding menu item: YouTube usage concept. This usage concept is regularly evaluated by us with regard to whether and how it is used. This evaluation of the usage concept is carried out regularly and takes into account usage figures and reach as well as the target group structure and usage behavior of the networks.

Further information on YouTube and other social networks and how you can protect your data can also be found at www.youngdata.de.

Status: December 2022

HWG LU's subscription to other YouTube users does not imply any statement about HWG LU's relationship with them or the content they publish. In particular, it does not imply any endorsement or recommendation of their followers. Rather, HWG LU views subscribing to other YouTube users* as a way to network with other bodies, individuals, and institutions for the purpose of quickly disseminating and learning about information relevant to higher education.

This also means that HWG LU will not automatically subscribe to all of its followers. Also, not subscribing to users* by HWG LU does not imply anything, in particular it does not imply rejection or disinterest of HWG LU towards them.

Manner and purpose of use

HWG LU uses its account mainly for its own video contributions and the sharing of other video contributions in the manner described by it in its usage concept . It will also respond to comments in selected cases, to the extent that this involves sharing information on university-related topics. For all types of inquiries, contact options outside of YouTube are primarily available, such as e-mails to: info@ 8< SPAM protection, please remove >8 hwg-lu.de . Detailed advice, for example on studying, is not provided; instead, a website link is provided to the relevant HWG LU telephone and email contacts.

YouTube and data protection

HWG LU's use of YouTube does not imply any endorsement of this medium or the company or the privacy policy of YouTube, LLC.

HWG LU encourages all users* to be aware of how their data is processed by YouTube and to protect their privacy as best they can: https://support.google.com/youtube/answer/2801895?hl=de. This includes reading the privacy policy of YouTube, LLC: https://support.google.com/youtube/answer/7671399?p=privacy_guidelines& hl=en&visit_id=636712289459742518-3880821460& rd=1. Key considerations are also summarized inHWG LU's own privacy policy on its YouTube use .

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

• Opening the user account only with the absolutely necessary data
• Deactivation of the widget function
• Prevent cross-site tracking (for example, by using the Ghostery add-on in the browser).

Status: December 2022

We do not tolerate offensive or illegal posts on our social media pages. In particular, refrain from

• Threats, bullying, harassment, insults, degradation, disparagement, insinuations, slander, defamation and hate speech in any form 
• Posts with attitudes/views that are xenophobic, sexist, or discriminatory towards minorities, communities, or individuals
• Posts that explicitly espouse partisan, religious, and/or ideological content and goals
• condoning, inciting or glorifying violence, war, discrimination, unconstitutional or anti-democratic acts
• pornographic or sadistic depictions

Do not post any advertising or spam.

• Any commercial content will be removed by us immediately.
• It is also not allowed to use the social networks to send advertising or other marketing content to others via private messages (spam).

Respect privacy and anonymity! Please help us to ensure the privacy and rights of other users*. Do not disclose personal/private details of other people, whether they are also users of the network or not. This includes primarily name, address and other personal information, but also photos/videos. Keep in mind that it may be difficult to delete them completely after the fact.

As a user of the site, respect the copyright and the right of intellectual property! In particular, make sure that you have the rights to distribute the content, photos, artworks or other works 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 continued use of such content on HWG LU's various social media sites.

"Watch your language!" There is nothing wrong with being informal and using dialect or colloquialisms, but no offensive language, profanity or the like will be tolerated. Neither will sexist remarks be tolerated. Remain friendly and tolerant! Even if you feel attacked or offended by a post/comment, remain factual and fair. If you feel that you have not been treated properly, please feel free to inform us. The easiest way to do this is by direct message to the page administrator* or by email to the HWG LU social media officers at hochschulkommunikation@hwg-lu.de.

To make the exchange accessible and understandable to all, please post only in German or English.

User comments, opinions, and links posted on social media pages operated by HWG LU do not necessarily reflect the opinion of HWG LU at . Furthermore, copyrighted works or trademarks of HWG LU may not be used without the prior written consent of the university.

All posts must have a specific, direct reference to the activities of HWG LU and comments must relate to the particular post being commented on. If in doubt, the respective site administrator* should be contacted before posting.

Posts/content that violate the principles formulated here will be removed immediately at . The author will be informed of this immediately. The author will be informed and admonished.

Users* who ignore the netiquette of our social media sites despite multiple warnings will be excluded from using our social media sites. Depending on the nature of the 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 page 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/.

It is not possible for us to check all postings of our users immediately. The site administrators can therefore not be held responsible or liable for the content of the comments. Rather, each user is responsible for his or her own contributions. We would like to point out that comments that violate applicable law are also subject to criminal prosecution on the Internet and can be reported to the police - by HWG LU or by users.

Status: December 2022