According to the general regulations of Art. 35 para. 1 of the European General Data Protection Regulation(GDPR), a data protection impact assessment must be carried out if 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 due to the nature, scope, circumstances and purposes of the processing. The "Framework for the use of social media by public bodies" of the Rhineland-Palatinate State Commissioner for Data Protection and Freedom of Information (LfDI) 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 Instagram offering of the Ludwigshafen University of Business and Society (HWG LU) itself does not trigger this consequence due to the very small scope of its own data processing (see the Instagram privacy policy). However, some of the postings have a direct personal reference. When creating and publishing its own content, HWG LU therefore ensures that the image rights of those depicted are taken into account in addition to the copyright of the photos. If reference is made to other Instagram users in HWG LU posts (by re-posting or mentioning), only the data that they have voluntarily provided themselves (user name and postings) is processed.

However, in the view of HWG LU, the use of Instagram itself constitutes high-risk processing due to its far-reaching effects with regard to the evaluation of the data by Meta Platforms Ireland Ltd, to which Instagram belongs, for advertising purposes and the like, for which a data protection impact assessment must be carried out.

This is because by using an Instagram account, the respective user is subject to systematic observation by Instagram. This can also reveal sensitive data such as political views, sexual orientation or health problems, which can be linked together and used to create a personality profile. People who are particularly vulnerable, such as young people, can also be Instagram users and therefore affected. Sensitive data can also be collected from them through the collection of log data, such as previously visited websites or the user's location data.

This is all the more true as Instagram cannot be checked or can only be checked to a limited extent. As the data of users based in Germany is not processed in Germany but in Ireland, there are higher hurdles to accessing (judicial) legal protection than with a company based in Germany.

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

Shared responsibility does not mean that the HWG LU confirms or guarantees the data protection compliance of Instagram's products. It cannot do this under the given circumstances. Rather, shared responsibility means that HWG LU makes itself and others aware of the risks of social networks. Social networks are currently in need of improvement in many areas from a data protection perspective. For this reason, Instagram users are shown alternative, more data protection-friendly communication channels by referring them to the HWG LU website.

Users are also made aware of the risks generally associated with the use of social media in the privacy policy of HWG LU's Instagram profile.

HWG LU has committed to these measures in its usage concept. The advantages and disadvantages of using Instagram are regularly evaluated in accordance with Instagram's terms of use. This evaluation of the usage concept takes place regularly and takes into account the usage figures and reach as well as the target group structure and usage behavior of the networks.

Instagram 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 HWG LU's Instagram use is as follows:

1. risk identification:

The risks described above, which are associated with the use of Instagram, exist in principle independently of HWG LU's own Instagram use. Also, in the vast majority of cases, the postings of HWG LU itself do not make any reference to sensitive personal data, but instead disseminate their own factual content.

Finally, the data that is processed through interaction with the Instagram profile of HWG LU or other profiles - namely the account name of an Instagram user visible in the comments - is already publicly/generally accessible/free on the internet.

However, by appearing on the Instagram profile of the HWG LU and the interaction, they are made available to a broader/"more specific" public and may thus achieve greater attention and wider distribution than without this interaction. Interest in the HWG LU can also be gauged by the subscriber status or regular contributions.

HWG LU's own Instagram usage therefore increases the amount of data that is used and analyzed by Instagram.

2.Risk analysis:

The expansion of the distribution circle and the increase in linking options encourages the processing of data for other purposes by Instagram and secret profiling. Openness to visitor contributions can also lead to adverse social consequences such as inappropriate or discriminatory comments or the dissemination of sensitive data.

While these damages may be significant if caused by Instagram itself, they are only increased to a limited extent by the Instagram profile of HWG LU. This is because a significant proportion of the data is already available to Instagram. In particular, the HWG LU's offer does not create any obligation to create an Instagram account, as there are sufficient alternative contact and information options for the HWG LU.

Also, the topics of campus life, science, education, research, etc. are only suitable for triggering hateful debates to a limited extent, so that the probability of damage occurring is very limited.

3.Risk assessment

Overall, the additional risk caused by the HWG LU Instagram profile can therefore be classified as low to medium.

It is also possible to implement remedial measures that further reduce the risk. A large part of these measures are the responsibility of the user: users can protect themselves to a certain extent by making various settings, such as deleting their browser history, deactivating cookies or not sharing their location when using photos.

In addition, continuous editorial support enables intervention in the event of comments that are defamatory or offensive to personality, up to and including blocking the account. HWG LU has formulated a netiquette for the use of its website, which it will ensure is adhered to when managing the site.

4. result

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

Status: January 2026

HWG LU uses the Instagram messaging service offered here via the technical platform and services of Facebook Inc, 1601 Willow Road Menlo Park, CA 94025: www.instagram.com/hwg.ludwigshafen/.

Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, is responsible for the data processing of persons living outside the United States.

We would like to point out that you use the Instagram profile offered here and its functions on your own responsibility. This applies in particular to the use of the interactive functions (e.g. liking and commenting).

The information and publications to be found on our Instagram profile are a voluntary additional offer. Visiting our Instagram profile is only possible for registered users of the Instagram platform. 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 Instagram:

Information on what data is processed by Instagram and for what purposes can be found in Instagram's privacy policy: https://help.instagram.com/155833707900388/.

HWG LU has no influence on the type and scope of the data processed by Instagram, the type of processing and use or the disclosure of this data to third parties. Nor does it have any effective control options in this respect.

By using Instagram, your personal data will be collected, transferred, stored, disclosed and used by Meta Platforms Ireland Ltd. and transferred to, stored and used in the United States, Ireland and any other country in which Meta Platforms Ireland Ltd. does business, regardless of your place of residence.

On the one hand, Instagram processes your voluntarily entered data such as name and user name, e-mail address, telephone number or the contacts in your address book when you upload or synchronize it.

On the other hand, Instagram also evaluates the content you share to determine which 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 on wireless networks or your IP address in order to send you advertising or other content.

Instagram may use analysis tools such as Instagram Insights or Google Analytics for evaluation purposes. HWG LU has no influence on the use of such tools by Instagram and has not been informed of such potential use. If tools of this kind are used for the Instagram profile of HWG LU, HWG LU has neither commissioned nor approved this nor supported it in any other way. Nor is the personal data obtained during the analysis made available to it. Only certain, non-personal, summarized information about the activity, such as the number of likes or clicks on a particular post or profile, can be viewed by HWG LU via its account. Furthermore, HWG LU has no way of preventing or disabling the use of such tools on its Instagram profile.

Via widgets integrated into websites and the use of cookies, Instagram is able to record your visits to these websites and assign them to your Instagram profile. This data can be used to offer you customized content or advertising. Accordingly, HWG LU refrains from using such widgets on its own websites.

Even if Instagram is a non-European provider that only has a European branch in Ireland, it is bound by the GDPR. This applies, for example, to your rights to information, blocking or deletion of data.

You have the option of restricting the processing of your data in the general settings of your Instagram profile under the various menu items listed there.

Further information on these points is available on the following Instagram support page:
https://help.instagram.com/519522125107875.

You can find out more about the possibility of viewing and downloading your own data from Instagram here: https://help.instagram.com/181231772500920.

Information about the conclusions Instagram draws about you can be found here:
https://help.instagram.com/181231772500920 and here https://help.instagram.com/155833707900388/

Information on the available personalization and data protection setting options can be found here: https://help.instagram.com/116024195217477.

You also have the option of sending data protection concerns and objections directly to Instagram via a form: https://help.instagram.com/contact/1845713985721890.

Information on the right to object to data processing by Instagram can be found here: https://help.instagram.com/contact/1845713985721890.

2 Data processed by HWG LU:

HWG LU also processes your data. It does not collect any data about your Instagram profile itself. However, the data you enter on Instagram, in particular your user name and the content published under your account, will be processed by us to the extent that we may comment on your posts or write posts from us that refer to your account. The data freely published and disseminated by you on Instagram is thus included by HWG LU in its offer and made accessible to its subscribers.

3 Rights, documentation, evaluation:

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 data protection officer: datenschutz@ 8< SPAM protection, please remove >8 hwg-lu.de.

You can find the current version of this privacy policy here. In the event of changes to the privacy policy, you will find the previous versions linked HERE.

The concept on which the offer is based can be found under the corresponding menu item: Instagram 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 takes into account the usage figures and reach as well as the target group structure of the networks.

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

Status: January 2026

Networking and communication with other Instagram profiles

Subscribing to or liking other Instagram profiles or liking posts or comments by HWG LU does not imply any statement about the relationship of HWG LU to these profiles or the content published by them. In particular, it does not imply any approval or recommendation for its subscribers. Rather, the HWG LU sees subscribing to other profiles or liking posts and comments as a way of networking with other bodies, persons and institutions for the rapid dissemination and knowledge of information related to university topics.

The HWG LU will not subscribe to all of its subscribers. Even if the HWG LU does not subscribe to a profile, this does not mean that the HWG LU rejects or is not interested in the respective profile.

Manner and purpose of use

HWG LU uses its Instagram profile for its own postings and reposts in the manner described in its usage concept. It can also be reached via direct messages and will respond to comments where appropriate, insofar as this involves the exchange of information on topics related to the university. For all types of inquiries, contact options outside of Instagram are primarily available, such as emails 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 telephone and email contacts at HWG LU.

Instagram and data protection

The use of Instagram by HWG LU does not constitute an endorsement of this medium or the company or the Instagram privacy policy. The HWG LU recommends that all users inform themselves about the processing of their data by Instagram and protect their privacy as much as possible: This includes reading Instagram's privacy policy. Key aspects are also summarized in the HWG LU's own privacy policy on its use of Instagram.

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

• Only open a user account with the data that is absolutely necessary
• Deactivate the widget function
• Prevent cross-page tracking (for example by using the Ghostery add-on in the browser)

Status: January 2026

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

• Threats, bullying, harassment, insults, degradation, slurs, insinuations, defamation, slander and hate speech in any form
• Posts with attitudes/views that are xenophobic, sexist or discriminatory towards minorities, communities or individuals
• Posts that explicitly represent party-political, religious and/or ideological content and goals
• endorsement, incitement or glorification of 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 immediately.
• It is also not permitted to use social networks to send advertising or other marketing content to others via private messages (spam).

Respect privacy and anonymity! Please help us to protect the privacy and rights of other users. Do not disclose any personal/private details of other people, regardless of whether they are also users of the network or not. This primarily includes name, address and other personal data, but also photos/videos. Please bear in mind that it may be difficult to delete these details completely at a later date.

As a user of the site, respect copyright and intellectual property rights! In particular, make sure that you have the rights to distribute the content, photos, works of art or other works protected by copyright, trademark or naming rights that you have published. By posting certain content, you confirm that you have the necessary permission to do so. You also consent to the further use of this content on the various social media pages of HWG LU.

"Watch what you say!" There is nothing wrong with being informal and using dialect or colloquial language, but no offensive language, swear words or the like will be tolerated. Nor will sexist remarks be tolerated. Remain friendly and tolerant! Even if you feel attacked or offended by a post/comment, remain objective and fair. If you feel you have been treated unfairly, you are welcome to let us know. The easiest way to do this is to send a direct message to the site administrator or email the HWG LU social media officer at hochschulkommunikation@hwg-lu.de.

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

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

All posts must have a concrete, direct reference to the activities of the HWG LU and comments must relate to the post commented on. In case of doubt, the respective site administrator should be contacted before posting.

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

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 here to the Facebook Community Standards: https://www.facebook.com/communitystandards/

It is not possible for us to check all of our users' posts immediately. The page administrators can therefore not be held responsible or liable for the content of the comments. Rather, each user is responsible for his/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: January 2026