For the message service provided in its online presence, the University of Stuttgart uses the technical platform and services of Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103 U.S.A. The body responsible for the data processing of persons who live outside of the United States is the Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland.
We wish to inform you that you are using the Twitter messaging service provided on this site and its functions under your own responsibility. This applies to the use of the interactive functions in particular (for example share, rate).
1. Data which is processed by Twitter:
Information concerning which data is processed by Twitter and for what purposes can be found in the data protection declaration of Twitter: https://twitter.com/de/privacy
Twitter Inc has undertaken to comply with the principles of the EU-US Privacy Shield. More information can be found via the following link: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active
The University of Stuttgart has no control over the scope of the data which is processed by Twitter or the type of processing and the use or disclosure of the said data to third parties. The University of Stuttgart also does not have any effective control options in this regard.
When using Twitter, your personal data will be recorded, transferred, saved, disclosed and used by Twitter Inc and will then, regardless of your place of residence, be transferred to the United States, Ireland and any other country in which Twitter Inc maintains a commercial presence and will be saved and used there.
During this process, Twitter processes the data which you have provided voluntarily on the one hand, such as your name and username, email address, telephone number and the contacts in your address book (should you upload or synchronize these) and on the other hand, Twitter also evaluates the content which you have shared, the topics you are interested in, it saves and processes confidential messages which you send directly to other users and can determine your location by means of GPS data, information concerning wireless networks and via your IP address, in order to provide you with advertising or other content.
For evaluation purposes, Twitter Inc may use analysis tools, such as Twitter or Google Analytics. The University of Stuttgart has no influence over the use of such tools by Twitter Inc and has not been informed of such potential use. Should such tools be used by Twitter Inc for the account of the University of Stuttgart, we have not requested or approved such use, nor have we supported this in any way. The personal data which is gathered during the analysis is also not made available to the University of Stuttgart. Only specific, non-personal information concerning the Tweet activity, such as the number of profile or link clicks can be viewed by the University of Stuttgart via its account. Furthermore, it is not possible for the University of Stuttgart to prevent or suspend the use of such tools in its Twitter account.
Twitter is then informed when you view content as an example, even if you have not created an account. This so-called “log data” can consist of the IP address, the browser type, the operating system, information concerning the previously accessed website and the sites visited by you, your location, your cellphone provider, the end device used by you (including device ID and application ID), the search terms used by you and cookie information.
By using Twitter buttons which are integrated into websites and widgets and by using cookies, Twitter can record your visits to these websites and assign such visits to your Twitter profile. On the basis of this data, content or advertising can be tailored to you. Accordingly, the University of Stuttgart does not use such buttons or widgets on its own websites.
Even though Twitter Inc is a provider headquartered outside of Europe which only maintains a presence in Ireland, it is still bound by the GDPR. For example, this regulates your rights of information and the right to have your data blocked or erased.
You have the option of restricting the processing of your data under the general settings of your Twitter account and under the point “data protection and security”. In addition, with mobile devices (smartphones, tablet computers), you can restrict the access of Twitter to contact and calendar data, photos, location data under the settings options there. However, this depends on the operating system being used.
Further information concerning these points can be found on the following Twitter support sites: https://support.twitter.com/articles/105576#
You can find information concerning the option to view your own data at Twitter via the following link: https://support.twitter.com/articles/20172711#
Information concerning the way in which you can be traced by Twitter can be found here: https://twitter.com/your_twitter_data
Information concerning the available personalization and data protection settings can be found here (with additional references): https://twitter.com/personalization
You also have the option of requesting information via the Twitter data protection form or archiving requests: https://support.twitter.com/forms/privacy
2. Data processed by the University of Stuttgart
The University of Stuttgart also processes your data, however it does not itself gather any data via your Twitter account. The data provided by you to Twitter, in particular your username and the content published under your account is however processed by us when we re-Tweet your posts or respond to these or also record Tweets which refer to your account. Any data which you freely publish and distribute in Twitter will be included by the University of Stuttgart in its services and made accessible to its followers.
3. Rights, documentation, evaluation:
Should you have any questions relating to our information services, you can contact us by email. You can claim your rights of information, blocking or the erasure of data by contacting our data protection officer.
The concept which forms the basis of the service can be found in the next section.
The University is characterized by its community of academic staff and students, the right of self-administration with the option of creating and carrying out one’s own study plans and research projects, as well as the authority to award publicly recognized academic titles. The University of Stuttgart is one of the leading technical universities in Germany, with a global reputation. It sees itself as a key player in university research, research which takes place outside of a university setting and industrial research, as well as a guarantor of quality and holistic, research-driven teaching. Public relations work is part of the University and will also take place in future via Twitter.
Twitter is a social network for short messages (microblogs). Via this service, registered users can publish short messages free-of-charge. These Tweets are of a limited length and can generally be viewed by anyone.
The users can register with other users as “followers” and receive their text messages.
Further information concerning Twitter can be found here: https://about.twitter.com/de.html
Twitter provides the following benefits:
- We can show contributions to multiple users in a speedy and uncomplicated manner at the same time.
- Users can read our Tweets without needing to register with Twitter.
- Allows us to promote ourselves fully externally.
2. Purpose of use
By setting up a Twitter channel, the existing communication channels such as the homepage, press releases and print products are complemented in a practical way and the Twitter channel informs the users of topics from the areas of research and university studies at the University of Stuttgart.
For certain target groups, the existing instruments are no longer sufficient. When taking the target group of journalists, researchers and students into account, we have found that more of these people can be reached more directly, more quickly and in a more up-to-date manner via Twitter and interested recipients can subscribe to corresponding Tweets.
We carry out research in the interest of the public and wish to provide the public with information in a direct and up-to-date manner. The Twitter channel enables broad distribution of our messages, better networking to our institutes and facilities, as well as to other universities and research institutions and allows a direct response to the relevant event.
3. Type and scope of use
The Twitter account informs the users of current topics in the area of research and university studies at the University of Stuttgart.
The regular content of the contributions includes the following:
- Information concerning current research plans and research projects
- Current information concerning semester dates, such as re-registration and registration for examinations
- Current information concerning upcoming events at the university
- Information about student activities
- Information about changes on campus
4. Responsibilities for editorial / technical support
The editorial support is the responsibility of the University Communications of the University of Stuttgart.
5. Alternative contact options
We wish to inform our users, that the Twitter channel is only one of many options for getting in touch with the University of Stuttgart or receiving information from us.
Further contact options:
- You can generally contact the central post room with any questions you may have.
Please note: Communication by email takes place without encryption as standard. When communicating by email, it cannot be excluded that unauthorized persons become aware of the content of an email when it is being sent.
Therefore, please use the encryption option when sending confidential information.
- Should you have any telephone queries, we can be contacted on +49 (0) 711 / 685-0 (the switchboard is manned from Monday to Friday from 6.45 am to 11.30 am and from 12.30 pm to 3.30 pm).
- Building and parcel address
Keplerstr. 7, 70177 Stuttgart
- Mailing address
Postfach 10 60 37 70049 Stuttgart
This use concept is evaluated once per calendar quarter in relation to whether and how the use takes place. We promote awareness on the part of the users concerning the risks to their right of informed self-determination.
A data protection consequence assessment must be carried out in accordance with the general rules of Article 35 Paragraph 1 of the European General Data Protection Regulation (GDPR) if a form of processing, in particular when using new technologies can be expected to represent a significant risk to the rights and freedoms of natural persons, in particular due to the type, scope, circumstances and purposes of the processing. The guidelines of the state officer for data protection and freedom of information (LfDI) concerning the use of social networks by public bodies imposes an obligation to carry out an assessment of the expected consequences of the intended processing for the protection of personal data in line with the GDPR.
The Twitter service of the University of Stuttgart itself does not lead to this consequence due to the limited scope of its own data processing (see also the data protection declaration of Twitter), in particular in relation to the fact that its Tweets merely concern the sending of content without any relationship to any person and, concerning other Twitter users, only the data which has been provided by such persons themselves and voluntarily (username and Tweets) is processed.
However, from the point of view of the University of Stuttgart, the use of Twitter represents processing with a significant risk due to its wide ranging effects, in particular in relation to the evaluation of the data by Twitter Inc for advertising purposes, which means that a data protection consequence assessment needs to be carried out (by Twitter).
Since by means of the use of a Twitter account, the respective user submits to the comprehensive observation of Twitter Inc. During this process, sensitive data such as political views, sexual orientation and health problems may also be disclosed, connected with each other and be used to create a personality profile. Persons subject to special protections, such as young people can be Twitter users and therefore data subjects. Even when reading Twitter in a purely passive manner without holding an account, sensitive data can be gathered through the obtaining of log data, for example by means of the previously visited websites or the location data of the user.
This applies even more when it is considered that this cannot be checked by Twitter Inc and it can only be verified in a limited manner. As the data of German users is not processed in Germany, rather in Ireland, there are major hurdles concerning redress before the courts compared to cases where the company is located in the country.
The University of Stuttgart proceeds on the assumption that public bodies which use a social network for public relations work and to provide general information must assume co-responsibility.
Co-responsibility does not mean that the University of Stuttgart is confirming or guaranteeing that the products of Twitter conform with data protection regulations. It is not possible for the University of Stuttgart to do so under the current circumstances. Rather, co-responsibility means that the University of Stuttgart is aware of the risks of social networks and makes others aware of these too. Currently, the social networks are considered to be in need of improvement from a data protection legislation point of view. Therefore, the Instagram users are shown alternative communication channels which better comply with data protection legislation by means of references on the homepage of the University of Stuttgart.
The risks which generally arise in connection with the use of social media are also explained to the users in the data protection declaration of the Twitter account of the University of Stuttgart.
The University of Stuttgart has undertaken to carry out these measures in its use concept in accordance with the regulations of the LfDI. In accordance with the use concept, the benefits and drawbacks of the use of Twitter are evaluated regularly, with the inclusion of the terms and conditions of use of Twitter Inc.
Therefore, the use of Twitter is included in a package of measures. The assessment of the consequences of the use Twitter by the University of Stuttgart can be explained as follows, taking the above into account:
1. Risk identification:
The risks referred to above which are connected to the use of Twitter generally exist regardless of the use of Twitter by the University of Stuttgart. Also, in the majority of cases of the Tweets by the University of Stuttgart, no connection is made to personal data, rather its own, factual content is distributed.
Finally, the data which is distributed when interacting with the Twitter account of the University of Stuttgart or other accounts, namely the Tweets and/or account name of a Twitter user, is already public / generally accessible and freely available on the Internet.
However, by means of the appearance on the Twitter page of the University of Stuttgart and the interaction, this data is made available to a wide ranging / "specific” target public audience, which means greater awareness and greater distribution than would be the case without such interaction. Also, because the University of Stuttgart follows other accounts or because others follow its account, additional cross connections and information concerning the respective Twitter user arise; for example, the interest in research topics and the follower characteristics or regular contributions can be followed. Finally, log data is gathered by Twitter even when the user reads the site in a passive manner.
By means of its own use of Twitter, the University of Stuttgart is therefore increasing the quantity of data which is used and evaluated by Twitter Inc.
2. Risk analysis
By means of the extension of the distribution group and the increase in the connection options, the processing of the data for other purposes by Twitter Inc and secret profile formation are encouraged. The openness for visitor contributions can lead to detrimental consequences for society, such as inappropriate or discriminatory comments or the distribution of sensitive data.
Should these consequences be shown to be significant when caused by Twitter Inc itself, these are increased to a limited extent by the Twitter profile of the University of Stuttgart, as the data is already available to Twitter Inc to a significant extent. In particular, the service provided by the University of Stuttgart does not lead to any obligation to set up a Twitter account, as enough other options for contacting the University of Stuttgart and obtaining information exist.
Also, the topics of science, teaching and research etc very rarely lead to hate filled debates being triggered, which means that the likelihood of detrimental consequences is extremely limited.
3. Risk assessment
Overall, the additional risk caused by the Twitter account of the University of Stuttgart is considered to be low to medium.
In addition, by using remedial measures, it is possible to further reduce the risk. However, the majority of these measures are the responsibility of the user: for example when using Twitter, there is no obligation to use a clear name. The user can protect himself or herself to a certain extent by means of various settings, for example by deleting his or her browser history, de-activating cookies or declining to provide location information when using photos.
In addition, the continual editorial support is able to intervene in case of comments which are defamatory or insult other persons up to and including blocking the account.
The use of Twitter by the University of Stuttgart is considered reasonable in light of the described risk and binding measures. The University of Stuttgart is obliged to observe future developments and regularly repeat and, where applicable, continually develop the assessment which has been carried out here.