Instagram

Netiquette

Dear followers and visitors,

We are very happy about a lively exchange on our social media pages.

To ensure a positive culture of discussion, we ask you to observe the following points when posting:

Maintain a polite and respectful tone: constructive criticism and factual comments are always welcome. However, insults and abusive language are not helpful and will be removed by us.
We do not tolerate any anti-constitutional, illegal, pornographic, racist, sexist, homophobic or other disparaging comments on our site. Anyone who violates this will be removed from the page and reported to Instagram.
Be aware that your posts on our page can be found publicly. Therefore, be careful with your own personal data and do not upload any third-party content (texts, photos, videos) without explicit consent.
Refrain from advertising, spam or other commercial content.
The Uniklinik Freiburg is ideologically neutral. Our social media pages are not suitable for the dissemination of religious or political messages.

Assessment of the consequences of Instagram 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 Instagram offering of the Medical Center - University of Freiburg itself does not trigger this consequence due to the very small scope of its own data processing (cf. in this respect the privacy policy on Instagram) does not trigger it. However, some of the postings 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 Instagram users in the posts of the Medical Center - University of Freiburg (by re-posting 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, the use of Instagram itself represents a high-risk processing operation due to its far-reaching effects with regard to the evaluation of data by Facebook Ireland Ltd, to which Instagram belongs, for advertising purposes, etc., for which a data protection impact assessment (by Instagram) must be carried out.

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

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

In this respect, the 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 Instagram's products. It cannot do this under the given circumstances. Rather, shared 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 areas from a data protection perspective. For this reason, Instagram 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 Instagram profile 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 Instagram are regularly evaluated in accordance with Instagram's terms of use.

Instagram use is thus embedded in a package of measures Against this background, the assessment of the consequences of Instagram use at the Medical Center - University of Freiburg is as follows:

1. risk identification:

The risks described at the beginning, which are associated with the use of Instagram, exist in principle independently of the Medical Center - University of Freiburg's own Instagram use Also, in the vast majority of cases, the postings of the Medical Center - University of Freiburg itself do not make any reference to sensitive personal data, but its own factual content is disseminated.

Finally, the data that is processed through interaction with the Instagram profile of the Medical Center - University of Freiburg or other profiles - namely the account name of an Instagram user visible in the comments - is already public/ generally accessible/ freely available on the Internet.

However, by appearing on the Instagram profile 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 the number of subscribers or regular posts.

By using Instagram itself, the Medical Center - University of Freiburg therefore increases the amount of data that is used and evaluated by Instagram.

2. Risk analysis:

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

While these damages may be significant if caused by Instagram itself, they are only increased to a limited extent by the Instagram profile of the Medical Center - University of Freiburg. This is because a significant proportion of the data is already available to Instagram. In particular, the Medical Center - University of Freiburg's offer does not create any obligation to create an Instagram 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, meaning that the probability of damage occurring is very limited.

3. Risk assessment

Overall, the additional risk caused by the Instagram profile 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 by making various settings, such as deleting their browser history, deactivating cookies or not sharing their location when using photos.

In addition, continuous editorial support allows users to intervene in the event of comments that are defamatory or offensive to their personality - up to and including blocking their 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 Instagram by the Medical Center - University of Freiburg is acceptable in view of the risks described and the binding measures provided for. 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.

Instagram usage concept of the University Medical Center 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 Instagram. 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 note our privacy policy and assessment of the consequences of Instagram use.

1. general information about Instagram

Instagram is a social network for photos and videos with short accompanying texts and for short stories consisting of several photos and/or videos. Registered users can use this service to publish their content free of charge, network with other users, comment on their posts and "like" them. Users can subscribe to profiles so that they can read their posts in their own Instagram feed. The advantages of Instagram are its wide reach and the use of hashtags to categorize and search for content by topic.

You can find more information about Instagram here: https://www.instagram.com/about/us/

2 Purpose of the use of Instagram by the Medical Center - University of Freiburg

The Instagram profile is a useful addition to existing communication channels such as the website, press releases, newsletters, print products and events. With the help of the Instagram profile, 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 gives the public an insight 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 Instagram, especially as interested recipients can simply subscribe to our profile. The Instagram profile allows us to share our photos, stories and impressions far and wide and to react immediately to what is happening.

Instagram 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 the university hospital's "listening medium", Instagram enables close, direct communication at eye level with its young target groups. Instagram can thus convey an informative, inviting and human image of the University Hospital.

3 Type and scope of use of Instagram by the Medical Center - University of Freiburg

The Instagram profile of the Medical Center - University of Freiburg informs users about 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 Instagram as a consultation channel. Inquiries that reach us via the Instagram news channel belonging to 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 www.instagram.com/uniklinik_fr/ are

Current events in which the Medical Center - University of Freiburg is involved
News about research at the Medical Center - University of Freiburg
Impressions from everyday life at the clinic and from employees of the Medical Center - University of Freiburg

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 Instagram profile is merely an additional option for contacting the Medical Center - University of Freiburg or receiving information from it. Alternatively, the information 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.

Pressemitteilungen