Reddit

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 site and reported to Reddit.
Be aware that your posts can be found publicly on our site. 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 Reddit 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 Reddit 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 (cf. in this respect the privacy policy), especially in view of the fact that its posts are mainly purely about sending content without personal reference, and in the case of a reference to other Reddit users, only the data that they have voluntarily provided themselves is processed (since Reddit is a career network, information on employer and position can often be found in addition to the user name and posts).

However, from the point of view of the Medical Center - University of Freiburg , the use of Reddit itself constitutes a high-risk processing operation due to its far-reaching effects, in particular with regard to the evaluation of data by Reddit for advertising purposes, etc., for which a data protection impact assessment (by Reddit) must be carried out.

This is because by using a Reddit account, the respective user comes under systematic observation by Reddit. 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. Particularly vulnerable persons such as young people can also be Reddit users and therefore affected, although they are naturally not part of the Reddit target group, even if official registration is permitted from the age of 16 (see also "Risk assessment").

Even if users merely passively read along on Reddit without their own account, sensitive data can be collected through the collection of log data, such as previously visited websites or the user's location data.

This is all the more true as Reddit cannot be checked or can only be checked to a limited extent. As the data of German users is not processed within Germany, but in non-European countries, there are higher hurdles for access to (judicial) legal protection than with a company based in Germany. If data protection issues cannot be resolved directly with Reddit, the data protection officer in Ireland is the point of contact.

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.
Joint responsibility does not mean that the Medical Center - University of Freiburg confirms or guarantees the data protection compliance of Reddit's products. 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, Reddit users are shown alternative, more data protection-friendly communication channels by referring them to the homepage of the Medical Center - University of Freiburg.

The risks generally associated with the use of social media are pointed out to users in the data protection declaration of the Medical Center - University of Freiburg. This can be found on the website of the Medical Center - University of Freiburg. Reddit itself does not currently offer a direct option for this on the Reddit company website. In addition, the Medical Center - University of Freiburg regularly runs campaigns to raise awareness and explain the risks on its homepage.

The Medical Center - University of Freiburg has committed to these measures in its usage concept . The advantages and disadvantages of using Reddit are regularly evaluated in accordance with the Reddit.com terms of use.

Reddit use is thus embedded in a package of measures. Against this background, the assessment of the consequences of Reddit 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 Reddit, exist in principle independently of the Medical Center - University of Freiburg's own Reddit use. Also, in the vast majority of cases, the contributions of the Medical Center - University of Freiburg itself do not make any reference to personal data, but rather disseminate their own factual content.

Finally, the data that is processed through interaction with the Reddit account of the Medical Center - University of Freiburg or other accounts - namely the posts and/or the account name of a Reddit user - is already public/ generally accessible/ freely available on the Internet.

However, by appearing on the Reddit 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.

The fact that the Medical Center - University of Freiburg follows other accounts or has them follow it also creates additional cross-connections and information about the respective Reddit user; for example, areas of interest can be read from the subscriber/follower property, regular contributions, activities and group memberships.

Finally, Reddit also collects log data when users passively read the site.

By using Reddit itself, the Medical Center - University of Freiburg thus increases the amount of data used and evaluated by Reddit.

2. Risk analysis:

By expanding the circle of dissemination and increasing the linking possibilities, the processing of data for other purposes by Reddit and secret profiling is favored. The openness for visitor contributions can also lead to adverse social consequences such as inappropriate or discriminatory comments or the dissemination of sensitive data or, as a career network, in particular with regard to the current or future workplace and professional environment.

While these damages may be significant if caused by Reddit itself, they are only increased to a very limited extent by the Reddit profile of the Medical Center - University of Freiburg. This is because a substantial part of the data is already available to Reddit. In particular, the Medical Center - University of Freiburg's offer does not create any obligation to create a Reddit account, as there are sufficient alternative contact and information options for the Medical Center - University of Freiburg. In principle, all posts and job offers that are displayed on the Reddit account of the Medical Center - University of Freiburg are also available on the website of the Medical Center - University of Freiburg, so that their consumption is possible without any data generation.

Also, the topics of the Medical Center - University of Freiburg, such as health, science, teaching, research, etc., are only suitable for triggering hateful debates to a limited extent, so that the probability of damage occurring is also very limited in this respect.

3. Risk assessment

Overall, the additional risk caused by the Reddit account 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. However, the majority of these measures are within the user's sphere of influence: 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.

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

This target group is generally much older and in possession of a corresponding education and must therefore weigh up the professional benefits of the service against the protection of their data. Nevertheless, it should be emphasized that there is an increased risk of fake profiles and identity theft, especially with business networks, as the business/professional environment of Reddit users is often described in detail.
In addition, some Reddit practices, such as pretending to be a member of existing Reddit user contacts and independently sending email invitations to join Reddit, can cause suspicion among Reddit users' acquaintances or even damage their professional reputation.
Reddit users should therefore be particularly advised to prohibit Reddit from accessing address books and other external services and to deactivate the automatic sending of email invitations, as Reddit also contacts contacts outside its own network and stores their data. For additional security, users can be advised to use Reddit only from the desktop in the browser and not to install any Reddit apps on their smartphone/mobile devices.

As a further remedial measure, continuous editorial support enables intervention in the event of defamatory or offensive comments, 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 Reddit by the Medical Center - University of Freiburg is justifiable 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.

Reddit usage concept of the Medical Center - University of Freiburg

With around 15,000 employees, the Medical Center - University of Freiburg is one of the largest university hospitals in Germany. In its original task, 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 Reddit. With the present 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 "Directive 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 Reddit use.

1. general information about Reddit

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

The Medical Center - University of Freiburg's Reddit company page is a useful addition to existing communication channels such as the website, press releases, newsletters, print products and events.

Social career networks are becoming increasingly important for success on the international job market. Reddit offers the advantage that we can reach these potential employees much more directly and quickly, especially with regard to our own employee recruitment, as interested users can simply subscribe to the company page. The Reddit presence of the Medical Center - University of Freiburg thus enables the widespread dissemination of posts and impressions of the Medical Center - University of Freiburg and the observation of the immediate reactions that follow.

Reddit can facilitate the communication of the Medical Center - University of Freiburg, as the target groups can contact the Medical Center of Freiburg with questions, suggestions or criticism in a low-threshold and uncomplicated manner. Reddit enables fast and uncomplicated communication at eye level and can thus convey an informative and inviting image of the hospital with its services, qualities and goals.

The Medical Center - University of Freiburg offers a wide range of career opportunities for international professionals. This results in a heterogeneous composition of employees and former employees, including those from outside German-speaking countries and non-European countries. Since many former employees of the Medical Center - University of Freiburg register independently on Reddit, the Medical Center - University of Freiburg uses the additional channel to inform its former employees worldwide about developments and topics at the Medical Center - University of Freiburg and to attract international employees to the Medical Center.

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

The Medical Center - University of Freiburg operates a company page on Reddit in the basic Reddit version with a logo and short profile.

The Reddit company page of the Medical Center - University of Freiburg informs users about current news from science, research and teaching and other interesting facts about everyday life at the hospital. Furthermore, the Medical Center - University of Freiburg displays its own job offers for the acquisition of qualified employees for 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 Reddit channel is merely an additional option for contacting the Medical Center - University of Freiburg or obtaining information from it. Alternatively, the information offered via Reddit can also be accessed via the corresponding links on our website at www.uniklinik-freiburg.de.

All inquiries can be directed 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

This utilization concept is evaluated by us 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.

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