Use of social media

On RWU's official social media channels, a polite, objective and respectful exchange is the basis for successful communication. To ensure this, the following rules of conduct apply to all users.

Please refrain from posting content that:

• is offensive, threatening, harassing or derogatory,
• expresses discrimination or hatred towards individuals or groups,
• contain racist, sexist or otherwise inhuman statements,
• deliberately spread religious, ideological or party-political beliefs,
• condone or glorify violence, war, anti-democratic or unconstitutional content,
• are pornographic, glorify violence or are sadistic.

Such content will be removed by us.

• Commercial content, advertising or spam are not permitted on our channels.
• Sending unsolicited advertising messages (spam) via direct messages is also prohibited.

Such content will be removed by us.

• Protect the privacy of others.
• Do not publish any personal data of third parties (e.g. names, addresses, photos or videos) without their express consent.
• Remember: It is not always possible to completely delete such content on the Internet.

• Only post content for which you have the corresponding rights of use.
• Pay attention to copyright, trademark and personal rights.
• By publishing content on our channels, you confirm that you are authorized to use it and that the content may be used on other RWU platforms.

• Remain friendly, respectful and tolerant - even in the event of differences of opinion.
• Posts containing swear words, insults or sexist language will not be tolerated.
• To ensure comprehensibility for everyone, please post in German or English. If you want to read content in a language that you do not speak, the portals usually provide appropriate translation tools.

• Posts that violate this netiquette will be removed.
• Repeated or serious violations may result in permanent exclusion from our social media channels.
• In particularly serious cases, we reserve the right to report content and users to the respective platform operators.

• All contributions should have a clear reference to Ravensburg-Weingarten University of Applied Sciences and its activities.
• Comments should refer specifically to the respective post.
• If you are unsure, our social media team will be happy to help.

• Every user is responsible for their own contributions.
• Illegal content can also be reported online and prosecuted.
• Third-party contributions do not necessarily reflect the opinion of the university.
• RWU trademarks and content protected by copyright may only be used with prior written permission.

Instagram is a platform on which users can share photos and videos - often with short texts. People who are registered can upload their own content, follow others, comment on posts or mark them with a "like" or other reactions. Anyone who follows a specific profile will see their posts in their own feed. The platform is particularly well known for its wide reach and the ability to use hashtags to organize content thematically and search for specific content.

Why RWU uses Instagram

Instagram complements RWU's existing means of communication - including the website, newsletter, printed publications and events - with a contemporary channel. The profile conveys a multifaceted picture of studying, research and campus life. The aim is to reach prospective students, strengthen the loyalty of current students and also involve alumni.

Instagram offers a direct way of addressing young target groups in particular, who can only be reached to a limited extent with traditional media such as print products or websites. Interested parties can follow the profile and easily stay up to date. Content can be distributed quickly and widely - reactions are often immediate.

In addition, Instagram not only serves to disseminate information, but also as a feedback channel: students and interested parties can easily ask questions, give feedback or make contact. The platform thus offers a low-threshold form of communication at eye level and helps RWU to appear open and approachable.

How RWU uses Instagram

On its Instagram profile, RWU provides information about the latest news from everyday university life, research, events and helpful offers for students. However, the channel is not used for individual advice. Inquiries via direct messages are forwarded to the relevant departments and referred to appropriate contact channels such as email or telephone.

Supervision

Responsibility for the content of RWU's central Instagram account lies with the Public Relations Office. The profile is managed by the responsible employees.

Further contact options

Instagram is merely a supplementary service. Information provided there can also be found via the official RWU website or other pages linked there. If you would like to get in touch with RWU, you will find alternative and direct communication channels on the website.

Further development

The usage concept for Instagram is regularly reviewed. This includes analyzing reach, user numbers and target groups in order to adapt and further develop the strategy.

According to Art. 35 para. 1 of the General Data Protection Regulation (GDPR), a data protection impact assessment is required if certain types of data processing - especially when using new technologies - are likely to result in a high risk to the rights and freedoms of natural persons. A guideline issued by the Baden-Württemberg State Commissioner for Data Protection and Freedom of Information also obliges public bodies to examine the data protection implications of using social networks.

The content published by RWU itself on Instagram does not generally involve any intensive processing of personal data. Nevertheless, individual posts may contain personal data, especially if users are referred to or their content is shared. In these cases, RWU limits itself to publicly accessible information such as user names or freely posted content and always observes copyright and personal rights.

The actual problem does not arise from RWU itself, but from the Instagram platform (a service of Meta Platforms Ireland Ltd.), which analyzes the personal data of its users extensively - e.g. for advertising purposes or to create profiles. This could also affect particularly sensitive information, such as political beliefs or health data. Young people, as a particularly vulnerable group, are also potentially affected.

Another point of criticism is the limited legal control over the platform, as the data processing takes place outside Germany - with correspondingly difficult access to legal remedies.

As a public institution that uses social media for public relations work, RWU recognizes its shared responsibility in terms of data protection law - without, however, being able to guarantee the data protection compliance of Instagram itself. Rather, its responsibility is aimed at informing users about possible risks and pointing out more data protection-friendly alternatives, for example by providing further information on its own website.

As part of its usage concept, RWU undertakes to regularly review the advantages and disadvantages of using Instagram. This analysis takes into account reach, user numbers and the behavior of the target groups. RWU's Instagram activities are embedded in a package of measures consisting of a usage concept, privacy policy, netiquette and legal disclaimer.

Risk identification

Even without your own profile, there is a certain data protection risk when using Instagram. Although RWU itself does not process sensitive data on a large scale, individual public posts or user interactions can achieve greater visibility than originally intended.

Risk analysis

Through interactions with the RWU profile, data can be better linked and used for profiling by Instagram. Even if sensitive comments or posts from outside are not frequent, there is always a risk of discriminatory or harmful content. However, the editorial team offers the option of moderating or removing such posts.

Furthermore, there is no obligation to use Instagram, as information is also accessible via other, more privacy-friendly channels.

Risk assessment

The additional risks posed by RWU's Instagram presence are assessed as low to moderate. Users also have the option of protecting their privacy by making their own settings (e.g. deactivating location services or cookies).

RWU actively supports this through continuous editorial support, formulated rules of conduct (netiquette) and a consistent response to violations.

Conclusion

The use of Instagram by RWU appears to be justifiable in view of the protective measures taken. RWU continuously monitors the development of the platform and the legal framework and regularly adapts its use and data protection strategy.

RWU maintains a public presence on the Instagram platform at: https: //www.instagram.com/rw.university/

The operator of the platform is

Meta Platforms Ireland Ltd.
4 Grand Canal Square
Grand Canal Harbour
Dublin 2, Ireland

Joint responsibility pursuant to Art. 26 GDPR

For the operation of the Instagram page, there is joint responsibility between Meta and RWU within the meaning of Art. 26 GDPR. The corresponding agreement can be viewed here: https: //www.facebook.com/legal/terms/page_controller_addendum

Meta assumes primary responsibility for the processing of personal data within the platform. RWU only receives anonymized statistics (insights) and has only limited influence on data processing by Meta.

Purpose of use

RWU uses Instagram for public relations, to provide information about studies, research and campus life and to communicate with students, interested parties and partners.

The legal basis for the use is Art. 6 para. 1 lit. e GDPR i.V.m. § Section 4 LDSG BW (performance of a task in the public interest).

Processing of personal data

When visiting our Instagram page, personal data of users is processed by Meta, including IP address, device information, interactions (likes, comments, messages) or usage behavior.

RWU itself only actively processes personal data if you interact with us, e.g. through comments or direct messages. In these cases, processing takes place on the basis of Art. 6 para. 1 lit. e GDPR i.V.m. § 4 LDSG BW.

Data transfer to third countries

Meta may transfer personal data to the USA or other third countries. Meta undertakes to comply with the EU Commission's standard contractual clauses to ensure an adequate level of data protection.

Your rights

As a data subject, you have the following rights

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object (Art. 21 GDPR)

To assert your rights against Meta, please contact Meta directly. With regard to the data processed by RWU, please contact

RWU Data Protection Officer
Email: datenschutz@rwu.de

Duration of storage

We only store data that you actively communicate to us via Instagram (e.g. via direct message) for as long as is necessary to fulfill the purpose.

Note on personal responsibility when using Instagram

Please note that the use of Instagram is your own responsibility. RWU has no influence on data processing by Meta and therefore recommends that you contact the provider directly if you have any data protection concerns.

Interaction with other Instagram profiles

If RWU follows other Instagram accounts and tags their posts or comments with "Like", this does not constitute an evaluation of the content or an official statement on the respective profiles or their posts. It does not constitute approval of the opinions expressed there or a recommendation of the content or followers there.

Rather, the interaction serves the purpose of networking with relevant actors - such as institutions, individuals or organizations - and to perceive and disseminate current information on relevant topics more quickly.

Not all RWU subscribers are subscribed back. The absence of a mutual connection should also not be interpreted as a rejection or lack of interest.

Aim and type of Instagram use

RWU's Instagram profile is used to publish its own content and occasional reposts, as set out in the usage concept. In addition, the channel is open for dialog via direct messages and comments, provided the posts relate to university-related topics.

For more comprehensive or formal concerns - such as student counseling - RWU expressly refers to alternative contact options outside of Instagram as well as the corresponding telephone numbers and contact pages on the official website.

Information on data protection on Instagram

RWU's presence on Instagram does not constitute an endorsement of the service or an endorsement of Instagram's (Meta Platforms Ireland Ltd.) corporate policy or privacy practices. Users are expressly encouraged to inform themselves about data processing by Instagram and to use the available privacy settings.

An overview of the most important aspects can be found in Instagram's own privacy policy.

Recommendations for the protection of privacy

To strengthen personal data protection when using Instagram, RWU recommends the following measures:

• Avoiding tracking through add-ons such as Ghostery in the internet browser
• Provide sparse information when registering, i.e. only the data that is absolutely necessary
• Deactivate widgets that can track user behavior across platforms

Facebook is a social network that enables the exchange of content such as texts, images, videos and links. Users can create profiles, join groups, follow pages, comment on posts and add reactions. The platform is used for both private communication and the public dissemination of information.

Why does RWU use Facebook?

Facebook adds an established channel with a wide reach to RWU's communication portfolio. The main target groups are prospective students, students, alumni and the interested public. The platform offers the opportunity to widely disseminate current information, event announcements and insights into university life.

Facebook is suitable for exchange and community building thanks to its group, event and comment functions. The platform is also a central digital location for many users.

How RWU uses Facebook

RWU uses its Facebook page to publish information on events, articles on research, teaching and everyday student life as well as service information for students. Individual advice is not provided via Facebook. Inquiries in comments or messages are referred to official channels (e-mail, website).

Support

RWU's central Facebook page is managed by the Public Relations Office. The content is edited and subject to quality and data protection standards.

Further contact options

Facebook is an additional service. All relevant information and contact options are also available on the official RWU website.

Further development

The usage concept for Facebook is regularly reviewed. Reach, target group interest and interaction behavior are incorporated into the further development of the strategy.

According to Art. 35 para. 1 of the General Data Protection Regulation (GDPR), a data protection impact assessment is required if certain types of data processing - in particular using new technologies - are likely to result in a high risk to the rights and freedoms of natural persons. A directive issued by the Baden-Württemberg State Commissioner for Data Protection and Freedom of Information also obliges public bodies to examine the data protection implications of using social networks.

The content published by RWU itself on Facebook does not generally involve extensive processing of personal data. However, individual posts may contain a personal reference - for example by linking to or naming users or sharing publicly posted content. In these cases, RWU restricts itself to freely accessible information such as profile names or published posts and consistently ensures that copyrights and personal rights are protected.

The central data protection issue does not lie with RWU itself, but with the Facebook platform (a service of Meta Platforms Ireland Ltd.). This platform analyses personal data of its users on a large scale - for example for advertising purposes, profiling or personalized content control. This could also involve particularly sensitive information - such as political views, religious beliefs or health status. Minors, who are part of the platform's target group, are also particularly vulnerable.

In addition, there is limited legal control over data processing, as this is carried out by Meta outside of Germany or the EU. This makes access to effective legal remedies or the enforcement of data subjects' rights more difficult.

As a public institution that uses social media for public relations purposes, RWU recognizes its shared responsibility in terms of data protection law. However, it cannot guarantee comprehensive data protection compliance of the Facebook platform. Instead, it sees its responsibility in particular in pointing out existing risks, promoting conscious use of the platform and pointing out more data protection-friendly information channels - such as the official RWU website.

As part of its usage concept, RWU undertakes to regularly evaluate the benefits and risks of using Facebook. This evaluation includes, in particular, reach, user numbers and the usage behavior of the target groups. RWU's Facebook presence is embedded in a comprehensive package of measures that includes a usage concept, a privacy policy, formulated rules of conduct (netiquette) and a legal disclaimer.

Risk identification

Even without your own Facebook account, there is a certain data protection risk when using Facebook. Although RWU itself does not process sensitive data on a large scale, public posts, shared content or user interactions can achieve greater visibility than originally intended. Due to the link with other meta services, user data can be analyzed more comprehensively.

Risk analysis

Through interactions with RWU's Facebook presence - such as comments, likes or sharing content - personal data can be linked to user profiles and used for comprehensive profiling by Facebook (meta). Even if sensitive or inappropriate content by third parties is rare, there is always a risk of discriminatory, politically extreme or harmful comments. These can be moderated by the editorial team and removed if necessary.

Furthermore, there is no obligation to use Facebook, as the information provided is also available via alternative, more data protection-friendly channels (e.g. the RWU website or newsletter).

Risk assessment

The risks associated with the operation of the Facebook presence are assessed as low to moderate. Users have the opportunity to influence their data processing through their own privacy settings (e.g. restricting visibility, deactivating location services, controlling advertising settings).

RWU contributes to the protection of users through active editorial support, formulated behavioral guidelines (netiquette) and a consistent response to violations.

Conclusion

The use of Facebook by RWU appears to be justifiable, taking into account the protective measures taken and the voluntary usability of the platform. RWU continuously monitors technical developments, changes in data protection law and the platform's business practices and adapts its use and data protection strategy accordingly.

Facebook page of the RWU: https://www.facebook.com/rw.university

Provider of the platform:
Meta Platforms Ireland Ltd.
4 Grand Canal Square
Grand Canal Harbour
Dublin 2, Ireland

Joint responsibility pursuant to Art. 26 GDPR

Meta and RWU are jointly responsible for the operation of the website. The corresponding agreement can be viewed at the following link: https://www.facebook.com/legal/terms/page_controller_addendum

Meta is responsible for the primary data processing. RWU only receives anonymized data and has no complete influence on data processing by Meta.

Purpose of use

• Public relations
• Information about studies, research and campus life
• Dialogue with target groups

Legal basis

Art. 6 para. 1 lit. e GDPR i. V. m. § Section 4 LDSG BW (task in the public interest)

Processing of personal data

Meta processes data independently when you visit the RWU Facebook page, including

• IP address, device information, location data
• Likes, comments, shared content
• Profile information (e.g. age, interests - if public)
• Usage behavior

RWU only processes personal data when users interact directly (e.g. through comments or messages).

Data transfer to third countries

Meta may transfer data to countries outside the EU, in particular to the USA. Meta ensures data protection through standard contractual clauses of the EU Commission, but there is no complete control by EU authorities.

Rights of data subjects

You have the following rights under the GDPR

• Information (Art. 15)
• Rectification (Art. 16)
• Erasure (Art. 17)
• Restriction (Art. 18)
• Data portability (Art. 20)
• Objection (Art. 21)

Contact:
Questions about processing by RWU:
📧 datenschutz@rwu.de

Requests to Meta:
📧 https://www.facebook.com/help/contact/540977946302970

Storage period:
Messages or comments received or answered by the RWU are only stored for as long as is necessary for processing.

Liking, commenting on or sharing content by RWU does not constitute an evaluation or support of the content. It only serves the purpose of visibility and networking within relevant subject areas.

No formal communication

Facebook does not replace official contact channels. For personal concerns, study advice or legally relevant communication, please refer to other channels (e.g. website, e-mail, telephone).

Note on personal responsibility

The use of Facebook is the sole responsibility of the user. RWU recommends informing yourself about Meta's data protection practices and using the available privacy settings.

Recommended protective measures for users

• Regularly check the privacy settings in your Facebook profile
• Deactivate location services and links to third-party providers
• Do not disclose sensitive information in comments or messages
• Use add-ons such as tracking blockers in your browser (e.g. uBlock, Ghostery)

TikTok is a video platform on which users can share and comment on short clips, usually set to music. The content is distributed via personalized feeds ("For You") as well as hashtags, trends and music. An algorithm-based suggestion mechanism is central to the visibility of posts.

Why does RWU use TikTok?

With TikTok, RWU is supplementing its existing communication channels - such as its website, newsletter, print media and Instagram - with a dynamic, visual platform that reaches younger target groups in particular. The aim is to address prospective students at a low threshold, provide insights into campus life and strengthen the university's visibility in new ways.

TikTok is particularly suitable for conveying knowledge in an entertaining and compact way, presenting student projects or drawing attention to events. At the same time, comments can be used to create dialog-oriented communication.

How RWU uses TikTok

RWU publishes short videos on TikTok on topics relating to studies, research, events, everyday life at the university and tips for students. The platform is not used for individual advice. Inquiries in comments or direct messages are referred to official contact channels (e.g. email or website).

Support

Editorial support is provided by the RWU Public Relations Office. Content is developed in close coordination with other relevant departments.

Further contact options

TikTok is a supplementary medium. All essential information can also be found on the official RWU website. It is possible to contact the university there at any time in a more data-efficient and direct way.

Further development

The use of TikTok is regularly evaluated. Reach, engagement and target group behavior are taken into account in order to adapt the strategy.

According to Art. 35 para. 1 of the General Data Protection Regulation (GDPR), a data protection impact assessment is required if certain types of data processing - in particular using new technologies - are likely to result in a high risk to the rights and freedoms of natural persons. A directive issued by the Baden-Württemberg State Commissioner for Data Protection and Freedom of Information also obliges public bodies to examine the data protection implications of using social networks.

The content published by RWU itself on TikTok does not generally involve extensive processing of personal data. However, individual posts may contain personal references - for example through the depiction of people, links, mentions of users or the sharing of publicly posted content. In such cases, RWU restricts itself to publicly accessible information and pays careful attention to compliance with copyright and personal rights.

The central data protection issue does not lie with RWU itself, but with the platform TikTok, operated by TikTok Technology Ltd (Ireland) and ByteDance Ltd (China). TikTok analyzes user data comprehensively - in particular for profiling, algorithmic control of content and for advertising purposes. There is a possibility that particularly sensitive information - such as political opinions, sexual orientation or health status - could also be affected. TikTok is aimed in particular at a young target group, including many minors, who are considered a particularly vulnerable group.

The lack of transparency in data processing, the far-reaching access options of the parent company ByteDance, which is based outside the EU, and the associated limited legal control are particularly criticized. The transfer of personal data to third countries (in particular to China and the USA) also makes it considerably more difficult to enforce the rights of data subjects.

As a public institution that uses social media for public relations purposes, RWU recognizes its shared responsibility in terms of data protection law. However, RWU cannot guarantee that the TikTok platform is fully compliant with data protection law. Rather, it sees its responsibility in informing users about existing risks, promoting the sensitive handling of personal data and actively offering data protection-friendly alternatives - especially via its own website.

As part of its usage concept, RWU undertakes to regularly assess the risks and potential of TikTok usage. This analysis takes into account developments in reach, target group behavior and technical and regulatory developments on the platform. RWU's TikTok presence is embedded in a package of measures that includes a usage concept, privacy policy, netiquette and legal information (disclaimer).

Risk identification

Even without your own TikTok account, there may be a data protection risk when accessing or sharing RWU content on TikTok. Although RWU itself does not carry out any extensive processing of sensitive data, publicly visible videos, comments or user interactions can have a greater reach than intended. Added to this is the algorithmic visibility control by TikTok, in which data links are made without transparency about the criteria.

Risk analysis

Through interactions with the RWU TikTok channel - e.g. through comments, likes or following the profile - personal data can be linked to user behavior and used for profiling and advertising purposes. Due to the predominantly audiovisual content, there is an additional risk that identifiable information (e.g. faces, voices, locations) will be processed and stored permanently.

Although moderation by the RWU editorial team makes it possible to delete or report inappropriate or sensitive content, there is still a certain residual risk, especially if problematic content is visible for a short time.

The use of TikTok is voluntary; all RWU content is also accessible via alternative, more data protection-friendly channels, such as the official website or a newsletter.

Risk assessment

The risks associated with the use of TikTok are assessed as moderate to increased - in particular due to the unclear transparency practices, international data transfer and algorithmic evaluation of user behavior. Although users have limited options to influence data processing (e.g. via privacy settings or deactivating personalized advertising), a relevant residual risk remains.

RWU counters these risks through editorial control, a clearly formulated usage concept, transparent information on data protection risks and the provision of alternative information offerings.

Conclusion

The use of TikTok by RWU can be considered acceptable, taking into account the protective measures taken and the voluntary nature of its use. RWU undertakes to continuously monitor developments relating to TikTok and the regulatory framework (in particular GDPR, EU-US Data Privacy Framework, third country transfers) and to adapt its usage concept and data protection measures accordingly if necessary.

RWU TikTok account: https://www.tiktok.com/@rwuniversity

Provider of the platform:
TikTok Technology Limited
10 Earlsfort Terrace
Dublin, D02 T380, Ireland

Joint responsibility according to Art. 26 GDPR

A contractual regulation on joint responsibility (Art. 26 GDPR) between TikTok and RWU is currently not publicly accessible or available in a standardized form, which is legally problematic.

Purpose of the use

Public relations, presentation of student life, communication with target groups (prospective students, students, alumni), low-threshold dissemination of information.

Legal basis

Art. 6 para. 1 lit. e GDPR i. V. m. § SECTION 4 LDSG BW

Data processing

TikTok collects personal data of users independently. RWU only receives anonymized insights (e.g. video views, interactions). RWU only actively processes personal data in the case of direct interaction (comments, messages).

Data transfer to third countries

TikTok may process data outside the EU. The protection of this data is the responsibility of TikTok. It is unclear to what extent an equivalent data protection control exists as under the GDPR.

Your rights

• Information (Art. 15 GDPR)
• Rectification (Art. 16 GDPR)
• Erasure (Art. 17 GDPR)
• Restriction of processing (Art. 18 GDPR)
• Data portability (Art. 20 GDPR)
• Objection (Art. 21 GDPR)

If you have any questions about your rights in connection with RWU, please contact

Data Protection Officer of RWU
E-mail: datenschutz@rwu.de

Interactions

When RWU links, comments on or follows TikToks from other accounts, this does not constitute an evaluation of the content or an official position. The interaction serves the purpose of visibility and networking, not content approval.

Limits of the medium

TikTok is not an official university communication channel for formal matters. Please use alternative contact channels (e.g. email or website) for confidential or advisory matters.

Recommended protective measures

• Activate privacy settings in the TikTok profile
• Restrict app access rights (e.g. to camera, microphone, location)
• Use pseudonymous accounts if desired
• Avoid publishing sensitive data in comments

YouTube is a video platform and social network that enables the sharing of audiovisual content and interaction in the form of comments, likes, subscriptions and community posts. Users can follow channels, share or comment on videos and create playlists.

Why does RWU use YouTube?

YouTube expands RWU's communication portfolio with a visual platform with a wide reach. The main target groups are prospective students, students, alumni and the interested public. The platform makes it possible to present information on studies, research and university life in a clear way and make it accessible to a wide audience.

How RWU uses YouTube

RWU uses its official YouTube channel to publish videos about study programs, campus life, events, research projects and services. The channel is primarily used for information and public relations, not for individual advice. Specific inquiries in comments are referred to official contact channels (e.g. website or email) where appropriate.

Support

The RWU YouTube channel is edited by the Public Relations Office. The content is prepared in accordance with journalistic and data protection standards.

Further contact options

YouTube is a supplementary service. All important information and services are also available on the official RWU website.

Further development

The usage concept is regularly reviewed and further developed. Findings from reach analyses, viewer interest and interaction behavior are incorporated into editorial and strategic planning.

According to Art. 35 para. 1 of the General Data Protection Regulation (GDPR), a data protection impact assessment is required if certain types of data processing - in particular using new technologies - are likely to result in a high risk to the rights and freedoms of natural persons. A directive issued by the Baden-Württemberg State Commissioner for Data Protection and Freedom of Information also obliges public bodies to examine the data protection implications of using social networks.

The content published by RWU itself on YouTube does not generally involve extensive processing of personal data. However, individual videos may contain a personal reference - for example through the depiction of people, links, names or the display of comments. RWU pays careful attention to compliance with copyright, personal rights and the rights of contributors and primarily uses its own or legally licensed material.

The central data protection issue does not lie with RWU itself, but with the YouTube platform, which is operated by Google Ireland Ltd, a subsidiary of Alphabet Inc (USA). YouTube collects extensive data about user behaviour - for example to create profiles, to personalize content and for advertising purposes. Personal data such as IP address, device information or location data can be collected and processed, particularly via embedded videos or use without a Google account.

In addition, Google also transfers data to third countries, in particular to the USA, where there is no level of data protection comparable to the GDPR. Although the implementation of the EU-US Data Privacy Framework provides a certain legal basis, risks remain with regard to the enforceability of data subjects' rights.

As a public institution, RWU recognizes its shared responsibility in the use of commercial platforms. Although it cannot guarantee YouTube's full data protection compliance, it provides transparent information about possible risks, educates users and also provides information about more data protection-friendly alternatives (such as its own website or media library).

As part of its usage concept, RWU regularly reviews the platform's data protection, technical and regulatory developments and adapts its measures accordingly. The YouTube presence is embedded in a package of measures that includes a usage concept, a privacy policy, netiquette and legal information (disclaimer).

Risk identification

Even without registering with YouTube, there may be a data protection risk when videos are accessed or embedded. User data is already transmitted to Google when a YouTube video is loaded - including IP address, timestamp and device data. This also applies when playing embedded videos on third-party sites such as rwu.de, unless they are embedded in a data protection-friendly manner (e.g. in extended data protection mode).

In addition, there is the possibility that recognizable persons or personal statements in the videos are made accessible to a broad public. Visibility is controlled by YouTube's recommendation and autoplay algorithms, the functioning of which is largely opaque.

Risk analysis

Interactions with the RWU YouTube channel - such as comments, likes or subscriptions - can link personal data with user behavior. Google potentially uses this data to create profiles and for targeted advertising. Users who are logged in with a Google account leave additional traces that can be linked to other services (e.g. Gmail, Google Search).

In audiovisual content, there is an increased risk that identifiable information - such as faces, voices, locations or license plate numbers - will be processed and made permanently available. RWU counters this risk through careful editorial planning, the de-identification of sensitive content where necessary and restrictive comment moderation.

The use of YouTube is voluntary. As far as possible, all RWU content is also accessible via alternative, more data protection-friendly channels (e.g. website, newsletter or internal university platforms).

Risk assessment

The risks associated with the use of YouTube are assessed as moderate. The decisive factors are the international data processing by Google, the lack of transparency in data linking and the possibility of comprehensive profiling. Although Google offers certain control elements (e.g. privacy settings, deletion functions), a relevant residual risk remains - especially for users with a Google account.

RWU takes these risks into account through

• editorial control and careful selection of content,
• using data protection-friendly embedding techniques,
• transparent references to data protection aspects,
• providing alternative information channels.

Conclusion

The use of YouTube by RWU can be assessed as acceptable - taking into account the protective measures described and the voluntary use by the target groups. RWU undertakes to continuously monitor developments relating to YouTube and the regulatory framework (GDPR, EU-US Data Privacy Framework, ECJ case law) and to adapt its usage concept and data protection measures as necessary.

YouTube channel of the RWU:
https://www.youtube.com/@RWUniversity

Platform provider:
Google Ireland Limited
Gordon House, Barrow Street
Dublin 4, Ireland
(subsidiary of Google LLC, USA)

Shared responsibility (Art. 26 GDPR)

When using the YouTube channel, there is joint responsibility between Google and RWU with regard to data processing. The primary responsibility for the processing of personal data lies with Google.

Information on data processing by Google:
https://policies.google.com/privacy

Purpose of use

• Public relations and university marketing
• Provision of information videos for prospective students
• Visualization of research, teaching and university culture
• Promotion of dialog with target groups

Legal basis

Art. 6 para. 1 lit. e GDPR i. V. m. § Section 4 LDSG BW (performance of public tasks)

Processed data (by Google/YouTube)

• IP address, location data, device information
• Usage behavior (viewing time, interaction with content)
• Channel subscriptions, likes, comments
• possibly linked data from other Google services (e.g. Gmail, Google Maps)

Data transfer to third countries

Google transfers data to the USA, among other countries. According to Google, this is protected by standard contractual clauses. Nevertheless, there is no complete control by EU authorities.

Rights of data subjects

According to the GDPR, you have the following rights in particular

• Information (Art. 15)
• Rectification (Art. 16)
• Erasure (Art. 17)
• Restriction (Art. 18)
• Data portability (Art. 20)
• Objection (Art. 21)

Inquiries to RWU (only regarding own data processing):
datenschutz@rwu.de

Contact Google:
https://support.google.com/youtube/answer/2801895?hl=de

Comments, likes or shared content by RWU do not constitute an evaluation or approval of the content, but serve to give visibility to relevant topics.

The YouTube channel does not replace official contact channels. For personal or legally binding concerns, please refer to e-mail, telephone or the RWU website.

Note on personal responsibility

The use of YouTube is your own responsibility. Users should be aware of data collection and processing by Google and regularly check their privacy settings in their Google account.

Recommended protective measures:

• Use YouTube in incognito mode or without a Google account
• Restrict the visibility of likes, subscriptions and comments
• Avoiding sensitive information in comments
• Use of tracking blockers or script blockers in the browser

LinkedIn is a professional social network that focuses on sharing professional content and maintaining professional contacts. Users can create profiles, follow companies, publish posts, comment and respond to content. The platform is used for both professional networking and the dissemination of institutional information.

Why does RWU use LinkedIn?

LinkedIn expands RWU's communication portfolio with a channel geared towards professional networks with a wide reach in the academic-professional environment. The main target groups are prospective students, students, alumni, research partners and the interested professional public. The platform enables the targeted dissemination of information on studying, research and career prospects.

LinkedIn is particularly suitable for quality-oriented visibility of the university due to its networking function, topic-related content and professional focus. Many users use LinkedIn as a central medium for obtaining information in a professional context.

How RWU uses LinkedIn

RWU uses its LinkedIn page to publish current information on research, teaching, events, personnel news and articles on university life and career topics. Individual advice is not provided via LinkedIn. Inquiries via comments or messages are referred to official channels (e.g. e-mail, website).

Support

RWU's central LinkedIn page is managed by the Public Relations Office. The content is created editorially and is subject to internal quality and data protection standards.

Further contact options

LinkedIn is a supplementary service. All relevant information and official contact channels are available on the RWU website.

Further development

The usage concept for LinkedIn is regularly reviewed. Reach, target group interest and interaction behavior are incorporated into the strategic development.

According to Art. 35 para. 1 GDPR, a data protection impact assessment is required if a form of data processing - in particular using new technologies - is likely to result in a high risk to the rights and freedoms of natural persons. In addition, a directive issued by the Baden-Württemberg State Commissioner for Data Protection and Freedom of Information obliges public bodies to examine the data protection implications of using social networks.

The content published by RWU on LinkedIn does not generally involve extensive processing of personal data. However, individual posts may contain personal references - e.g. by naming employees, sharing profiles, photos of events or through interactions with other users. RWU pays attention to a legally compliant and restrained presentation and to compliance with copyright and personal rights.

However, the main data protection issue does not lie with RWU, but with the LinkedIn platform, operated by LinkedIn Ireland Unlimited Company (for users in the EU), a subsidiary of the US-based Microsoft Corporation. LinkedIn collects extensive personal data, in particular for the analysis of career networks, for profiling and for personalized advertising and algorithmically controlled content. Data from people who are not logged in can also be collected through third-party tracking, cookies or embedding.

International data processing - including transfer to third countries such as the USA - entails risks with regard to the enforceability of data subjects' rights. Despite the EU-US Data Privacy Framework, there are concerns about an equivalent level of data protection outside the EU.

As a public university, RWU is aware of its shared responsibility when handling personal data. It cannot guarantee comprehensive data protection compliance of the LinkedIn platform, but is committed to transparency, informing users about existing risks and providing alternative information via its own website or internal university channels.

The use of LinkedIn is embedded in an overarching package of measures that includes a usage concept, a privacy policy, netiquette and legal information (disclaimer). RWU regularly evaluates developments on the platform and adapts its measures accordingly.

Risk identification

A data protection risk already exists when visiting or viewing content on LinkedIn, even without a user account. Personal data such as IP address, location, browser information and usage habits can be collected and linked to other Microsoft data sources.

When interacting with the RWU channel or sharing RWU content, further personal data may become publicly visible, especially if users act with their real name and profile picture. Visibility via company networks and contact connections can also lead to unintended reach.

Risk analysis

By interacting with RWU's LinkedIn channel - e.g. through comments, likes, reposts or following - personal data can be processed and used for analysis and advertising purposes. Due to the business orientation of LinkedIn, there is a particular interest in professional data, qualifications, network connections and communication behavior.

Even if content is editorially checked before publication, there is a residual risk of content created by third parties being visible for a short time or unwanted contexts in the context of advertising and profile links.

The voluntary use of the platform by the target group (especially students, alumni, employees, cooperation partners) mitigates the risk. All essential RWU information is also provided via alternative, more data protection-friendly channels.

Risk assessment

The risks associated with the use of LinkedIn are assessed as moderate. The platform offers some controls to manage privacy and visibility, but data processing by LinkedIn or Microsoft remains opaque and involves international data sharing.

Significant risk factors:

• Comprehensive analysis of user behavior and network structures,
• algorithmically controlled content without comprehensible criteria,
• lack of complete control over third-party data processing.

RWU responds to this with:

• editorial control and restrained naming of personal data,
• clear netiquette and moderation of comments,
• Reference to data protection aspects,
• use of alternative communication channels.

Conclusion

The use of LinkedIn by RWU can be considered acceptable, taking into account the aforementioned protective measures and the voluntary nature of use. RWU continuously monitors regulatory and technical developments, particularly with regard to third country transfers and GDPR compliance, and will adapt its usage concept if necessary.

LinkedIn page of the RWU: https://www.linkedin.com/school/hochschule-ravensburg-weingarten/

Provider of the platform:
LinkedIn Ireland Unlimited Company
Wilton Plaza, Wilton Place
Dublin 2, Ireland

Joint responsibility pursuant to Art. 26 GDPR

There is joint responsibility between LinkedIn and RWU for the processing of personal data when operating the LinkedIn company page. The corresponding agreement is available at the following link:
https://legal.linkedin.com/pages-joint-controller-addendum

LinkedIn is primarily responsible for data processing. RWU receives aggregated, anonymized data and has no complete influence on data processing by LinkedIn.

Purpose of use

• Public relations work
• Information about studies, research and campus life
• Exchange with interested parties and partners

Legal basis

Art. 6 para. 1 lit. e GDPR i. V. m. § Section 4 LDSG BW (task in the public interest)

Processing of personal data

LinkedIn independently processes data when you visit the RWU website, including

• IP address, device information, location data
• Reactions, comments, shared content
• Profile data (if public)
• Usage behavior

RWU only processes personal data in the case of direct interaction (e.g. comments, messages).

Data transfer to third countries

LinkedIn may transfer data to countries outside the EU, in particular to the USA. EU standard contractual clauses are used, but there are restrictions with regard to protection by European data protection authorities.

Rights of data subjects

You have the following rights under the GDPR

• Information (Art. 15)
• Rectification (Art. 16)
• Erasure (Art. 17)
• Restriction (Art. 18)
• Data portability (Art. 20)
• Objection (Art. 21)

Questions about processing by RWU:
datenschutz@rwu.de

Requests to LinkedIn:
https://www.linkedin.com/help/linkedin/ask/TSO-DPO

Storage period:
Comments or messages to RWU are only stored for as long as is necessary for processing.

Reacting to content (e.g. through likes or comments) by the RWU does not constitute an evaluation of content, but serves to increase visibility within thematically relevant networks.

No formal communication

LinkedIn does not replace official RWU communication channels. Other channels should be used for personal or legally relevant matters (website, email, telephone).

Note on personal responsibility

The use of LinkedIn is your own responsibility. RWU recommends that you familiarize yourself with the platform's data protection guidelines and actively use the available privacy settings.

Recommended protective measures for users

• Check privacy settings regularly
• Deactivate location services and third-party access
• Do not post sensitive information in comments or messages
• Use privacy add-ons in the browser (e.g. uBlock, Ghostery)