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) makes the assessment of the consequences of the intended processing operations for the protection of personal data within the meaning of the GDPR mandatory.

The LinkedIn offer of HWG LU itself does not trigger this consequence due to the only very limited scope of its own data processing (see the privacy policy on LinkedIn), especially with regard to the fact that its posts are mainly a pure sending of content without any personal reference, and in the case of a reference to other LinkedIn users*, only the data that they have provided themselves and voluntarily is processed (since LinkedIn is a career network, in addition to the user name and posts, information on employer and position can often be found).

However, from the perspective of the HWG LU, the Linkedin 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 LinkedIn for advertising purposes and the like, for which a data protection impact assessment must be carried out.

By using a LinkedIn account, the respective user places himself or herself under systematic observation by LinkedIn. 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 LinkedIn users and thus affected parties, although these naturally tend not to belong to the LinkedIn target group, even if official registration is already permitted from the age of 16. Even when merely passively reading LinkedIn 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 since LinkedIn cannot be audited or can only be audited to a limited extent. Since the data of German users is not processed within Germany but in non-European countries, there are higher hurdles for access to (judicial) legal protection than with a company based in Germany.

In this respect, 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.

Co-responsibility does not mean that HWG LU confirms or guarantees the data protection conformity of LinkedIn'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, LinkedIn users are shown alternative, more data protection-friendly communication channels by means of references to the HWG LU homepage.

The risks generally associated with the use of social media are pointed out to users in HWG LU's privacy policy for LinkedIn.

HWG LU has committed itself to these measures in its usage concept . Advantages and disadvantages of LinkedIn use are then regularly evaluated with the inclusion of the LinkedIn Corporation's terms of use. This evaluation of the usage concept is carried out regularly and takes into account the usage figures and ranges as well as the target group structure and usage behavior 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 by HWG LU is as follows:

1. risk identification:

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

Finally, the data processed through interaction with HWG LU's LinkedIn account or other accounts - namely the posts or/and the account name of a LinkedIn user - are already publicly/generally accessible/free on the Internet.

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

Also, by HWG LU following or being followed by other accounts, additional cross-relationships and information about the particular LinkedIn user or user are created; for example, areas of interest can be gleaned from subscriber/follower property, regular posts, activities, and group memberships.

Finally, log data is also collected by LinkedIn when users passively read the page.

Thus, through its own LinkedIn usage, HWG LU increases the amount of data that is used and analyzed by LinkedIn.

2. Risk analysis:

By expanding the circle of distribution and increasing the linking possibilities, the processing of data for other purposes by LinkedIn and surreptitious profiling is favored. Also, openness to visitor contributions may lead to adverse social consequences such as inappropriate or discriminatory comments or the dissemination of sensitive data, or as a career network, especially in relation to the current or future workplace and professional environment.

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

Also, the topics of the HWG LU, such as science, teaching and  research, 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 LinkedIn account of the 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. However, a large part of these measures are the responsibility of the user: the user* can protect him/herself to a certain extent through various settings, such as deleting his/her browser history, deactivating cookies or not sharing the location when using photos.

With regard to persons particularly worthy of protection, such as young people, it can be seen that they are generally not part of the LinkedIn target group. Even though it is possible to register with LinkedIn from the age of 16, LinkedIn as a career network is mainly aimed at specialists and executives who want to network with each other worldwide of their own accord.

This target group is usually significantly older and in possession of the appropriate education and must therefore weigh up for themselves between the professional benefits of the service and the protection of their data. Nevertheless, it should be emphasized that there is an increased risk of fake profiles and identity theft, particularly in the case of business networks, as the business/professional environment of LinkedIn users is often described in detail.

In addition, some LinkedIn practices, such as pretending to be members of LinkedIn users' existing contacts and independently sending 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 e-mail invitations, since LinkedIn also contacts contacts outside its own network and stores their data. For additional security, users can be advised to use LinkedIn only from the desktop in the browser and not to install LinkedIn apps on their smartphone/mobile device.

As a further corrective measure, continuous editorial support enables intervention in the case of comments that violate honor or personality, up to and including account blocking. HWG LU has formulated a netiquette for the use of its service, which it will ensure is observed when managing the site.

4. result

The LinkedIn use by HWG LU is justifiable in view of the described risks 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

HWG LU 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/school/hwg-ludwigshafen  

The data controller for individuals living in the designated countries of the GDPR (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 page offered here and its functions on your own responsibility. This applies in particular to the use of the interactive functions (for example, 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 logged-in users of the LinkedIn platform. Alternatively, you can also access all information offered via this page on our website at www.hwg-lu.de .

1. data processed by LinkedIn:

Information on what data is processed by LinkedIn and for what purposes can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy.

With respect to the collection, use, and storage of personal data provided to LinkedIn by users from the designated countries of the GDPR, LinkedIn Corporation and its U.S. subsidiaries ("LinkedIn") follow the standard contractual clauses approved by the European Commission.

For more information, please visit https://www.linkedin.com/help/linkedin/answer/62533?trk=microsites-frontend_legal_privacy-policy&lang=en.

HWG LU has no influence on the type and scope of the data processed by LinkedIn, the manner in which this data 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. Likewise, HWG LU has no knowledge of the content of your data transmitted to LinkedIn and cannot provide any information about what data is stored about you through the use of the LinkedIn service.

By using LinkedIn, your personal data is collected, transmitted, stored, disclosed and used by LinkedIn Corporation. In doing so, LinkedIn transfers your data from the countries designated in the GDPR to the United States of America (USA) and back. Currently, LinkedIn's data centers for storing its members' information are located in the U.S. and Singapore.

LinkedIn collects and processes, for example, location and device information as well as internet protocol addresses (IP addresses) in addition to your voluntarily entered data such as profile, login, contact and calendar data. Using cookies or similar technologies, LinkedIn can also identify you outside of its own services and across different devices.

LinkedIn collects and analyzes data from the content, news and messages you post and upload, 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 states that it may use your personal information to provide you with additional services (including advertisements), including using automated systems and its own inferences, and to customize them to be more relevant and useful to you and others.

To do this, LinkedIn may also aggregate data internally across various services covered in its privacy policy (details available at https://www.linkedin.com/legal/privacy-policy#use).

In what way LinkedIn uses the data from visits to LinkedIn pages for its own purposes, to what extent activities on the LinkedIn page are assigned to individual users*, how long LinkedIn stores this data and whether data from a visit to the LinkedIn page is passed on to third parties, is not conclusively and clearly stated by LinkedIn and is not known to HWG LU.

Further, LinkedIn states it may use the services of third parties (affiliates and third-party service providers) to assist it in providing its services (for example, maintenance, analysis, auditing, payment, fraud detection, marketing and development).

These third parties 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 HWG LU's LinkedIn page, HWG LU has not commissioned, approved or otherwise supported this in any way. Nor 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 post or page, is viewable by HWG LU through its account. Moreover, HWG LU has no way to prevent or disable 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 public LinkedIn profile). This so-called "log data" may be the IP address, browser type, operating system, information about the website you previously visited and the pages you viewed, your location, your mobile carrier, the terminal device you use (including device ID and application ID), the search terms you used and cookie information.

Via LinkedIn buttons or widgets embedded in websites and the use of cookies, it is possible for LinkedIn to record your visits to these websites and associate them with your LinkedIn profile. Based on this data, content or advertising can be offered tailored to you.

Accordingly, HWG LU refrains from using such buttons and widgets on its own websites. Even though the LinkedIn Corporation is a non-European provider, it is bound by the GDPR in the designated countries. This concerns, for example, your rights to information, blocking or deletion of data.

You have options to restrict the processing and visibility of your data in your account navigation under the item "Settings and Privacy" under the various menu items listed there.

Please note that all information you enter in your profile is visible to the public by default, i.e. members who log into 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" tags or the "Follow" function. Group memberships are also publicly visible.

When you share posts, the default setting is for this to be public. In the options, you can limit the visibility of these posts to your contacts. You can also specify in the settings on LinkedIn whether you want to share your contact list with all your contacts. Through a so-called public profile, your content is also discoverable outside of LinkedIn and in search engines.

More information on these points is available on the following pages of the LinkedIn help: https://www.linkedin.com/help/linkedin.

The option to view and download your own data on LinkedIn can be found 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 comprehensive data collection and other privacy settings options, please visit: http://www.linkedin.com/legal/privacy-policy.

The option to opt out of interest-based advertising (not advertising in general) can be found here: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Furthermore, for questions regarding the privacy policy or user agreement, you have the option to contact LinkedIn via the LinkedIn contact form or via LinkedIn's office responsible for the Designated Countries in Ireland:

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 Place,
Dublin 2, Ireland.

You may request that LinkedIn delete a portion of your personal data (for example, if it is no longer necessary to provide services to you) using the contact methods listed above.

However, there are also data uses that you cannot influence via the settings.

If you fundamentally disagree with such use, your only option is to close your account: https://www.linkedin.com/psettings/account-management/close-submit.

If you are located in one of the designated countries of the GDPR, 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 HWG LU Processed Data:

HWG LU also processes your data. Admittedly, it does not collect any data itself via its LinkedIn account. However, the data you enter on LinkedIn, in particular your username and the content published under your account, is processed by us insofar as we may share your postings or comment on them, or also make postings from us that refer to your account. The data you freely publish and disseminate on LinkedIn is thus included by HWG LU in its offering and made available to its followers and subscribers*.

3. rights, documentation, evaluation:

If you have any questions about our information offering, you can reach us at info@ 8< SPAM protection, please remove >8 hwg-lu.de . You can assert your rights to information, blocking or deletion of data by contacting 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: LinkedIn 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 ranges as well as the target group structure of the networks.

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

Status: December 2022

Networking and communication with other LinkedIn profiles.

Subscribing to or liking other LinkedIn profiles, or liking posts or comments by HWG LU, does not imply any statement about HWG LU's relationship with those profiles or the content they publish. In particular, it does not imply any endorsement or recommendation for its subscribers*. Rather, HWG LU views subscribing to other profiles or liking posts and comments as a way to network with other institutions, individuals, and entities for the purpose of quickly disseminating and becoming aware of information that is related to university issues.

HWG LU will not subscribe to all of its subscribers*. Also, HWG LU's failure to subscribe to a profile does not imply anything; in particular, it does not imply HWG LU's rejection of or disinterest in the profile in question.

Manner and purpose of use

HWG LU uses its LinkedIn profile for its own postings in the manner described by it in its usage concept . It will also respond to comments, where appropriate, to the extent that this involves sharing information on topics related to the university. For all kinds of inquiries, contact options outside of LinkedIn 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.

LinkedIn and data protection

HWG LU's use of LinkedIn does not imply any endorsement of this medium or the company or LinkedIn's privacy policy. HWG LU recommends that all users* be aware of how their data is processed by LinkedIn and protect their privacy as much as possible: This includes reading LinkedIn's privacy policy. Key points are also summarized inHWG LU's own privacy policy on its LinkedIn use .

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

• Opening the user account only with the data that is absolutely necessary.
• 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
• approve, trigger or glorify 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