According to the general regulations 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 "Framework for the use of social media by public bodies" issued by the State Commissioner for Data Protection and Freedom of Information  Rhineland-Palatinate (LfDI) makes it mandatory to assess the consequences of the intended processing operations for the protection of personal data within the meaning of the GDPR.

The  XING offerof HWG LU itself does not trigger this consequence due to the very small scope of its own data processing (see the privacy policy for XING). However, the postings often have a direct personal reference. When creating and publishing its own content, the LU HWG therefore ensures that the image rights of those depicted are taken into account in addition to the copyright of the photos.

However, in the view of HWG LU,  XING use itself constitutes high-risk processing due to its far-reaching effects with regard to the evaluation of data by XING for advertising purposes and the like, for which a data protection impact assessment must be carried out due to the joint responsibility of the site operator (HWG LU) and service provider (XING).

This is because by using a XING account, the respective user is subject to systematic observation by XING. 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.

In this respect, HWG LU assumes that, as a public body that uses a social network for public relations work and to provide general information, it bears joint responsibility.

Shared responsibility does not mean that HWG LU confirms or guarantees the data protection compliance of XING SE's products. It cannot do this under the given circumstances. Rather, shared responsibility means that HWG LU 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, XING users are shown alternative, more data protection-friendly communication channels on the HWG LU website.

Users are also made aware of the risks generally associated with the use of social media in the privacy policy on HWG LU's XING company page.

HWG LU has committed to these measures in its usage concept . The advantages and disadvantages of using XING are regularly evaluated in accordance with XING SE's terms of use. This evaluation of the usage concept takes place regularly and takes into account the usage figures and reach as well as the target group structure and usage behavior of the networks.

XING usage is thus embedded in a package of measures (usage concept, privacy policy, disclaimer and netiquette). Against this background, the assessment of the consequences of HWG LU's use of XING is as follows:

1. risk identification:

The risks described at the beginning, which are associated with the use of XING, exist in principle independently of the HWG LU's own XING use. Also, in the vast majority of cases, the postings of the LU HWG itself do not make any reference to sensitive personal data, but instead disseminate their own factual content.

Finally, the data that is processed through interaction with the XING company page of HWG LU or other accounts - namely the account name of a XING user visible in the comments - is already publicly/generally accessible/free on the internet.

However, by appearing on the XING company page of HWG LU 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 interest in the HWG LU can also be seen from the follower property or regular contributions. Finally, log data is also collected by XING when users passively read the XING company page.

HWG LU's own use of XING therefore increases the amount of data that is used and analyzed by XING SE.

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 XING SE 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 XING SE itself, they are only increased to a limited extent by HWG LU's XING company page. This is because the data is largely available to XING SE anyway. In particular, there is no obligation to create a XING account as a result of HWG LU's offer, as there are sufficient alternative contact and information options for HWG LU.

Also, topics such as science, education and research 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 XING company page of HWG LU can therefore be classified as low to medium.

It is also possible to implement remedial measures that further reduce the risk. Many of these measures are the responsibility 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. However, unlike Twitter, for example, XING officially requires a real name.

In addition, the continuous editorial support allows for intervention in the event of comments that are defamatory or offensive to personality, up to and including blocking the account. HWG LU has formulated a netiquette for the use of its website, which it will ensure is adhered to when managing the site.

4. result

The use of XING by HWG LU is justifiable in view of the risks described and the binding measures envisaged. HWG LU undertakes to monitor further developments and to regularly repeat and, if necessary, further develop the review carried out here.

Status: December 2022

HWG LU uses the XING messaging service offered here via the technical platform and services of XING SE, Dammtorstraße 30, 20354 Hamburg, Germany: https://www.XING.com/pages/hochschulefurwirtschaftundgesellschaftludwigshafen.

XING SE, Dammtorstraße 30, 20354 Hamburg, Germany, is responsible for data processing.

We would like to point out that you use the XING company page offered here and its functions under your own responsibility. This applies in particular to the use of the interactive functions (for example, sharing, rating, commenting).

The information and publications to be found on our XING page are a voluntary additional offer. Visiting our XING page is only possible for registered users of the XING platform. Alternatively, you can access the study or work-related information offered via this page on our website at www.hwg-lu.de .

1. data processed by XING:

Information on what data is processed by XING and for what purposes can be found in XING's privacy policy: https://privacy.XING.com/de/datenschutzerklaerung.

HWG LU has no influence on the type and scope of the data processed by XING, the way in which it is processed and used, or the transfer of this data to third parties. Nor does it have any effective means of control in this respect.

When you use XING, your personal data is collected, transmitted, stored, disclosed and used by XING SE. This data may be transferred to any other country in which XING SE or its partners do business and stored and used there, regardless of your place of residence. According to XING, this is always done in compliance with the conditions set out for this by the DSGVO .

On the one hand, XING processes your voluntarily entered data such as name and username, e-mail address or telephone number or the contacts in your address book when you upload or synchronize this.

On the other hand, XING also evaluates the content you share to determine what topics you are interested in, stores and processes confidential messages that you send directly to other users, and can determine your location using GPS data, wireless network information, or your IP address in order to send you advertising or other content.

XING SE may use analysis tools such as Google Analytics for evaluation purposes. HWG LU has no influence on the use of such tools by XING SE and has not been informed about such potential use. If tools of this type are used by XING SE for the HWG LU company website, HWG LU has neither commissioned nor approved this nor supported it in any other way. Nor is it provided with the personal data obtained during the analysis. Moreover, HWG LU has no way of preventing or disabling the use of such tools on its XING corporate site.

Via XING buttons or widgets embedded in websites and the use of cookies, it is possible for XING to record your visits to these websites and assign them to your XING profile. This data can be used to offer content or advertising tailored to you. Accordingly, HWG LU refrains from using such buttons and widgets on its own websites.

Since XING SE is a European provider, it is bound by the DSGVO . This concerns, for example, your rights to information, blocking or deletion of data.

You have options for restricting the processing of your data in the general settings of your XING account under the menu item "Privacy".

You can find out about the possibility of viewing and downloading your own data on XING here: https://www.XING.com/settings/privacy/data/disclosure.

Information about the inferences drawn about you by XING can be found here:
https://privacy.XING.com/de/datenschutzerklaerung/allgemeine-hinweise.

Information on the available personalization and data protection setting options can be found here: https://privacy.xing.com/de/ihre-privatsphaere.

Furthermore, you have the option of contacting XING's data protection officer directly by letter or e-mail: Felix Lasse, Dammtorstraße 30, 20354 Hamburg, Germany, e-mail: datenschutzbeauftragter@ 8< SPAM protection, please remove >8 xing.com.

Information on rights of objection with regard to data processing by XING can be found here: https://privacy.XING.com/de/datenschutzerklaerung/welche-rechte-koennen-sie-geltend-machen.

Information on the complaints office responsible for XING SE can be found here:
https://privacy.XING.com/de/datenschutzerklaerung/welche-rechte-koennen-sie-geltend-machen/beschwerderecht.

2. Data processed by HWG LU:

HWG LU also processes your data. It does not collect any data itself via its XING account. However, the data you enter on XING, in particular your username, is processed by us insofar as we give you the opportunity to comment on our postings or also make postings from us that refer to your account. The data you freely publish and disseminate on XING is thus included by HWG LU in its offering and made available to its fans and subscribers.

3. rights, documentation, evaluation:

If you have any questions about our information offering, you can contact us at info@ 8< SPAM protection, please remove >8 hwg-lu.de . You can assert your rights to information, blocking or deletion of data by contacting our data protection officer: datenschutz@ 8< SPAM protection, please remove >8 hwg-lu.de.

You can find the current version of this data protection declaration here. In the event of changes to the data protection declaration, you will find the previous versions linked.

You can find the concept on which the offer is based under the corresponding menu item XING usage concept. This usage concept is regularly evaluated by us with regard to the "whether" and "how" of the usage. This evaluation of the usage concept takes into account usage figures and reach as well as the target group structure of the networks.

Further information on XING and other social networks and how you can protect your data can also be found at www.youngdata.de.

Status: December 2022

Networking and communication with other XING users

The fact that HWG LU likes or comments on other XING users' comments on its own XING company page does not imply any statement whatsoever about HWG LU's relationship with these users or the content published by them. In particular, it does not imply any approval or recommendation for their followers. Rather, HWG LU views liking or replying to comments as a way to network with other users* for quick dissemination and knowledge of information related to science.

HWG LU will not like or comment on all comments made on its corporate page. The fact that HWG LU does not like or comment on a user's comment does not mean that HWG LU disagrees with or is not interested in the user.

Manner and purpose of use

HWG LU uses its company page for its own postings in the manner described by it in its usage concept . Where appropriate, it will respond to comments insofar as this involves the exchange of information on topics related to higher education. For all types of inquiries, contact options outside of XING are primarily available, such as e-mails to: info@ 8< SPAM protection, please remove >8 hwg-lu.de. Detailed advice, for example on studying, is not provided; instead, a website link refers users to the relevant telephone and e-mail contacts at HWG LU.

XING and data protection

The use of XING by HWG LU does not imply any endorsement of this medium or the company or XING's privacy policy. HWG LU recommends that all users* inform themselves about how their data is processed by XING and protect their privacy as much as possible: This includes readingXING's privacy policy. Key points are also summarized in HWG LU's own privacy policy on its use of XING.

In addition, every user should at least make the following settings to protect their privacy:

• Only open a user account with the data that is absolutely necessary.
• Deactivation of the widget function
• Prevent cross-page tracking (for example, by using the Ghostery add-on in the browser).

Status: December 2022

We do not tolerate offensive or illegal posts on our social media pages. In particular, refrain from

• Threats, bullying, harassment, insults, degradation, disparagement, insinuations, slander, defamation and hate speech in any form 
• Posts with attitudes/views that are xenophobic, sexist, or discriminatory towards minorities, communities, or individuals
• Posts that explicitly espouse partisan, religious, and/or ideological content and goals
• approve, trigger or glorify violence, war, discrimination, unconstitutional or anti-democratic acts
• pornographic or sadistic depictions

Do not post any advertising or spam.

• Any commercial content will be removed by us immediately.
• It is also not allowed to use the social networks to send advertising or other marketing content to others via private messages (spam).

Respect privacy and anonymity! Please help us to ensure the privacy and rights of other users*. Do not disclose personal/private details of other people, whether they are also users of the network or not. This includes primarily name, address and other personal information, but also photos/videos. Keep in mind that it may be difficult to delete them completely after the fact.

As a user of the site, respect the copyright and the right of intellectual property! In particular, make sure that you have the rights to distribute the content, photos, artworks or other works protected by copyright, trademark or name. By posting certain content, you confirm that you have the necessary permission to do so. In addition, you consent to the continued use of such content on HWG LU's various social media sites.

"Watch your language!" There is nothing wrong with being informal and using dialect or colloquialisms, but no offensive language, profanity or the like will be tolerated. Neither will sexist remarks be tolerated. Remain friendly and tolerant! Even if you feel attacked or offended by a post/comment, remain factual and fair. If you feel that you have not been treated properly, please feel free to inform us. The easiest way to do this is by direct message to the page administrator* or by email to the HWG LU social media officers at hochschulkommunikation@hwg-lu.de.

To make the exchange accessible and understandable to all, please post only in German or English.

User comments, opinions, and links posted on social media pages operated by HWG LU do not necessarily reflect the opinion of HWG LU at . Furthermore, copyrighted works or trademarks of HWG LU may not be used without the prior written consent of the university.

All posts must have a specific, direct relationship to the activities of HWG LU and comments must relate to the particular post being commented on. In case of doubt, the respective site administrator* should be contacted before posting.

Posts/content that violate the principles formulated here will be removed immediately at . The author will be informed of this immediately. The author will be informed and admonished.

Users* who ignore the netiquette of our social media pages despite multiple warnings will be excluded from using our social media pages. Depending on the nature of the content and/or the intensity of the insult, discrimination, threat, etc., we reserve the right to report this incident and the user* to the respective page provider. These all have their own community standards, which also form the basis of our netiquette. As an example, we refer to the community standards of Facebook: https://www.facebook.com/communitystandards/.

It is not possible for us to check all postings of our users immediately. The site administrators can therefore not be held responsible or liable for the content of the comments. Rather, each user is responsible for his or her own contributions. We would like to point out that comments that violate applicable law are also subject to criminal prosecution on the Internet and can be reported to the police - by HWG LU or by users.

Status: December 2022