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Netiquette
Dear followers and visitors,
We are very happy about a lively exchange on our social media pages.
For a positive culture of discussion, we ask you to observe the following points when posting:
Privacy policy
The University Medical Center Freiburg, Breisacher Straße 153, 79110 Freiburg, uses the Facebook messaging service offered here (hereinafter referred to as the "Service") via the technical platform and services of Facebook Inc, 1601 Willow Road Menlo Park, CA 94025 (hereinafter referred to as the "Provider"): https://www.facebook.com/UniklinikFreiburg/
Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, is responsible for the data processing of persons living outside the United States.
The use of this service is not required to contact us or to receive our information. Information that we publish via this service can also be accessed in the same or similar form via the website of the Uniklinik Freiburg University Center - University of Freiburg at www.uniklinik-freiburg.de.
You can also contact us at any time via kommunikation@uniklinik-freiburg.de.
We would like to point out that you use the service offered here and its functionalities at your own risk. This applies in particular to the use of interactive Facebook functions, such as sharing or commenting.
The data collected about you when you use the service will be processed by the provider and may be transferred to countries outside the European Union. The Freiburg University Medical Center has no influence on the type and scope of the data processed by the provider, the type of processing and use or the transfer of this data to third parties, in particular to countries outside the European Union.
Information on what data is processed by the provider and for what purposes can be found in the privacy policy of the service: https://www.facebook.com/privacy/explanation.
Assessment of the consequences of Facebook use by the Medical Center - University of Freiburg
According to the general rule of Art. 35 para. 1 of the European General Data Protection Regulation (GDPR), a data protection impact assessment must be carried out if a form of processing, in particular when using new technologies, is likely to result in a high risk to the rights and freedoms of natural persons due to the nature, scope, circumstances and purposes of the processing. The guideline of the State Commissioner for Data Protection and Freedom of Information (LfDI) on the use of social networks by public bodies makes it mandatory to assess the consequences of the intended processing operations for the protection of personal data in accordance with the GDPR.
The Facebook offer of the Medical Center - University of Freiburg itself does not trigger this consequence due to the very small scope of its own data processing (see the Facebook privacy policy ). However, the postings often have a direct personal reference. When creating and publishing its own content, the Medical Center - University of Freiburg therefore ensures that the image rights of those depicted are taken into account in addition to the copyright of the photos. If reference is made to other Facebook users in the contributions of the Medical Center - University of Freiburg (by sharing or mentioning), only the data that they have voluntarily provided themselves (user name and postings) will be processed.
However, from the point of view of the Medical Center - University of Freiburg , Facebook use in itself represents a high-risk processing operation due to its far-reaching effects with regard to the evaluation of data by Facebook Ireland Ltd. for advertising purposes, etc., for which a data protection impact assessment must be carried out due to the joint responsibility of the site operator (Medical Center - University of Freiburg) and the service provider (Facebook).
This is because by using a Facebook account, the respective user comes under the systematic observation of Facebook Ireland Ltd. This can also reveal sensitive data such as political views, sexual orientation or health problems, which can be linked together and used to create a personality profile. People who are particularly vulnerable, such as young people, can also be Facebook users and therefore data subjects. Sensitive data can be collected through the collection of log data, such as the websites previously visited or the user's location data, even if the user merely passively reads along on Facebook without an account.
This is all the more true as Facebook Ireland Ltd. cannot be checked or can only be checked to a limited extent. As the data of users based in Germany is not processed in Germany but in Ireland, there are higher hurdles for access to (judicial) legal protection than with a company based in Germany.
In this respect, the Medical Center - University of Freiburg assumes that public bodies that use a social network for public relations work and to provide general information bear joint responsibility.
Shared responsibility does not mean that the Medical Center - University of Freiburg confirms or guarantees the data protection compliance of the products of Facebook Ireland Ltd. It cannot do this under the given circumstances. Rather, co-responsibility means that the Medical Center - University of Freiburg makes itself and others aware of the risks of social networks. Social networks are currently in need of improvement in many respects from a data protection perspective. For this reason, Facebook users are shown alternative, more data protection-friendly communication channels by referring to the homepage of the Medical Center - University of Freiburg .
Users are also made aware of the risks generally associated with the use of social media in the privacy policy of the Facebook fan page of the Medical Center - University of Freiburg
The Medical Center - University of Freiburg has committed to these measures in its usage concept. The advantages and disadvantages of using Facebook are regularly evaluated in accordance with the terms of use of Facebook Ireland Ltd.
Facebook use is thus embedded in a package of measures . Against this background, the assessment of the consequences of Facebook use by the Medical Center - University of Freiburg is as follows:
1. risk identification:
The risks associated with the use of Facebook described at the beginning exist in principle independently of the Medical Center - University of Freiburg's own Facebook use. Also, in the vast majority of cases, the postings of the Medical Center - University of Freiburg themselves do not make any reference to sensitive personal data, but rather disseminate their own factual content.
Finally, the data that is processed through interaction with the Facebook fan page of the Medical Center - University of Freiburg or other accounts - namely the account name of a Facebook user visible in the comments - is already public/ generally accessible/ freely available on the Internet.
However, by appearing on the Facebook fan page of the Medical Center - University of Freiburg and the interaction, they are made available to a broader/"more specific" public and may thus achieve greater attention and wider distribution than without this interaction. Interest in the Medical Center - University of Freiburg can also be gauged by fan or subscriber status or regular contributions. Finally, Facebook also collects log data when users passively read the fan page.
Through its own Facebook use, the Medical Center - University of Freiburg thus increases the amount of data used and evaluated by Facebook Ireland Ltd.
2. Risk analysis:
The expansion of the dissemination circle and the increase in the number of possible links favors the processing of data for other purposes by Facebook Ireland Ltd. and secret profiling. Openness to visitor contributions can also lead to adverse social consequences such as inappropriate or discriminatory comments or the dissemination of sensitive data.
While these damages may be significant if they are caused by Facebook Ireland Ltd. itself, they are only increased to a limited extent by the Facebook fan page of the Medical Center - University of Freiburg . This is because a significant proportion of the data is already available to Facebook Ireland Ltd. In particular, the Medical Center - University of Freiburg website does not compel users to create a Facebook account, as there are sufficient alternative contact and information options for the Medical Center - University of Freiburg .
Furthermore, the topics of health, science, teaching, research, etc. are only suitable for triggering hateful debates to a limited extent, so that the probability of damage occurring is very limited.
3. Risk assessment
Overall, the additional risk caused by the Facebook fan page of the Medical Center - University of Freiburg can therefore be classified as low to medium.
It is also possible to implement remedial measures that further reduce the risk. A large part of these measures lie within the sphere of the user: Users can protect themselves to a certain extent through various settings, for example by deleting their browser history, deactivating cookies or not sharing their location when using photos. However, unlike Twitter, for example, Facebook officially requires a real name.
In addition, the continuous editorial support enables intervention in the event of comments that are defamatory or offensive to personality, up to and including blocking the account. The Medical Center - University of Freiburg has formulated a netiquette for the use of its website, which it will ensure is adhered to when maintaining the site.
4. result
The use of Facebook by the Medical Center - University of Freiburg is justifiable in view of the risks described and the binding measures provided. The Medical Center - University of Freiburg undertakes to monitor further developments and to regularly repeat and, if necessary, further develop the review carried out here.
Facebook usage concept of the Medical Center - University of Freiburg
With around 12,000 employees, the Medical Center - University of Freiburg is one of the largest university hospitals in Germany. In its original mission, the University Medical Center combines patient care, research and teaching, always with the aim of offering patients treatment based on the latest scientific findings today and in the future.
Public relations work for the Medical Center - University of Freiburg also takes place on Facebook. With this usage concept, the Medical Center - University of Freiburg assumes its responsibility and role model function for the use of social media as a public body in accordance with the "Guidelines of the State Commissioner for Data Protection and Freedom of Information (LfDI) on the use of social networks by public bodies". Please also refer to our privacy policy and assessment of the consequences of Facebook use.
1 General information about Facebook
Facebook is a social network for texts, photos, videos and live streams. Registered users can use this service to publish their content free of charge, connect with other users or fan pages, comment on, like and share their posts.
Users can like or subscribe to fan pages so that they can read their posts in their own news feed.
The advantages of Facebook are its wide reach and - in contrast to some other social networks - its readability without the need for users to register themselves. Fan page content can also be read by users without logging in to Facebook.
You can find more information about Facebook here: https://de.newsroom.fb.com/company-info/
2 Purpose of the use of Facebook by the Medical Center - University of Freiburg
The Facebook fan page is a useful addition to existing communication channels such as the website, press releases, newsletters, print products and events. With the help of the Facebook fan page, a diverse picture of medical treatment, teaching, research and life at the Medical Center - University of Freiburg can be drawn, which both appeals to interested parties and increases the identification of employees with their employer. It also provides the public with insights into the working methods, research and teaching at the Medical Center - University of Freiburg and the work of the Medical Center - University of Freiburg facilities.
For some target groups, the "classic" tools alone (print and website) were no longer sufficient. Particularly with regard to the target group of specialists and employees, we have found that we can reach them much more directly and quickly via Facebook, especially as interested recipients can simply subscribe to our fan page. The Facebook fan page allows us to share our news, stories and impressions far and wide and to react immediately to what is happening.
Facebook is also a channel for communication and listening. Patients, relatives, employees and interested parties can contact the University Hospital with questions, suggestions or criticism in a low-threshold and uncomplicated manner. As a "listening medium", Facebook enables the University Hospital to communicate closely and directly with its target groups at eye level. Facebook can thus convey an informative, inviting and human image of the University Hospital.
3 Type and scope of use of Facebook by the Medical Center - University of Freiburg
The Facebook fan page of the Medical Center - University of Freiburg informs users about current reports on medical topics, events, news from science, research and teaching, service offers, job offers and other interesting facts about everyday life at the hospital. However, we do not use Facebook as a consultation channel. Inquiries that reach us via the Facebook news channel associated with the page are forwarded directly to the relevant department and referred to communication channels such as telephone and email.
Regular content of the posts on the Facebook fan page of the Medical Center - University of Freiburg are:
4. responsibilities for editorial/technical support
Responsibility for editorial support lies with Benjamin Waschow, Head of Corporate Communications and Press Spokesperson, and the associated Corporate Communications department, in particular the social media team.
5 Alternative information and contact options
We would like to point out to users that the Facebook channel is merely an additional option for contacting the Medical Center - University of Freiburg or receiving information from it. Alternatively, the information offered via Facebook can also be accessed via the corresponding links on our website at www.uniklinik-freiburg.de or on the other linked websites.
You can generally direct all inquiries to the central Corporate Communications inbox at kommunikation@uniklinik-freiburg.de. You can also reach the social media team at kommunikation@uniklinik-freiburg.de.
You can reach the Medical Center - University of Freiburg by telephone on 0761 270-0. The switchboard is manned 24 hours a day.
Visiting address:
Hugstetter Straße 55
79106 Freiburg
You can find an overview of the various ways to contact the Medical Center - University of Freiburg here: www.uniklinik-freiburg.de/so-finden-sie-uns/lageplaene
6. voluntary commitment
We evaluate this utilization concept once a year with regard to whether and how it is used. This evaluation of the usage concept takes into account the usage figures and reach as well as the target group structure of the networks.
You can find the newsroom of
University of Freiburg
here

