Twitter

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 the relevant platform.
Be aware that your posts on our site can be found publicly. Therefore, be careful with your own personal data and do not upload any content (texts, photos, videos) from third parties 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 Twitter 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 Twitter 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 Twitter), especially in view of the fact that its tweets are mainly purely about sending content without personal reference, and in the case of a reference to other Twitter users, only the data that they have voluntarily provided themselves (user name and tweets) is processed.

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

This is because by using a Twitter account, the respective user comes under the systematic observation of Twitter Inc. 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 Twitter users and therefore affected. 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 Twitter without an account.

This is all the more true as Twitter Inc. 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 Twitter Inc. 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, Twitter users are shown alternative, more data protection-friendly communication channels by referring them 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 Medical Center - University of Freiburg's Twitter account

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

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

1. risk identification:

The risks associated with the use of Twitter described at the outset exist in principle independently of the Medical Center - University of Freiburg's own Twitter use Also, in the vast majority of cases, the tweets of the Medical Center - University of Freiburg itself make no reference to personal data, but instead disseminate their own factual content.

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

However, by appearing on the Twitter 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 that they follow them, also creates additional cross-connections and information about the respective Twitter user; for example, interest in the Medical Center - University of Freiburg can be seen from the follower property or regular contributions. Finally, log data is also collected by Twitter when users passively read the page.

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

2. Risk analysis:

The expansion of the dissemination circle and the increase in linking options favors the processing of data for other purposes by Twitter Inc. 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 Twitter Inc. itself, they are only increased to a very limited extent by the Twitter profile of the Medical Center - University of Freiburg. This is because a substantial part of the data is already available to Twitter Inc. In particular, the Medical Center - University of Freiburg's offer does not create any obligation to create a Twitter 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 Twitter 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. The majority of these measures lie within the sphere of the user: For example, there is no obligation to use a clear name when using Twitter. Users can also 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 enables users to intervene 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 social media offerings, which it will ensure is adhered to when managing the site.

4. result

Twitter use 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.

Twitter 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 Twitter. 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 "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 Twitter use.

1. general information about Twitter

Twitter is a social network for short messages, photos and videos. Registered users can publish short messages free of charge via this service. These tweets have a limited length and are usually visible to everyone.
Users can "follow" other users so that they can read their messages in their own Twitter feed.

The advantages of Twitter are its wide reach and - in contrast to some other social networks - its readability without the need for the user to register, as well as its usability without the use of a real name.

You can find more information about Twitter here: https://about.twitter.com/de.html

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

The Twitter channels are a useful addition to the existing communication channels, such as the website, press releases, newsletters, print products and events. The Twitter channels primarily inform users about the latest news from the Medical Center - University of Freiburg.

For some target groups, the "classic" instruments alone (print, website, mailing) were no longer sufficient. Especially with regard to the target group of journalists and politicians, but also with regard to the scientific (research) community and employees, we have found that we can reach them much more directly, quickly and on a daily basis via Twitter, especially since interested recipients can subscribe to corresponding tweets. The Twitter channel allows us to disseminate our messages far and wide, network better with other institutions and sources of information and react immediately to what is happening.

Furthermore, direct dialogue with readers enables us to obtain opinions and feedback in order to optimize our scientific, organizational and communicative work.

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

The Twitter account of the Medical Center - University of Freiburg informs users about current press releases, events, news from science, research and teaching as well as other interesting facts about everyday life at the hospital. However, we do not use Twitter as a service or advisory channel.

Regular content of the posts on @Uniklinik_Fr are:

News about research and work at 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 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.

Pressemitteilungen