Privacy Notice
- 1. Data controller and Data Protection Officer
- 2. Information for data subjects under Articles 13 and 14 of the GDPR
- 3. Automated decision-making
- 4. Transfer of data to third countries
- 5. Your rights
- 6. Website
- 7. Contacting the Commissioner via publicly accessible contact options
- 8. Newsletters
- 9. Media relations
- 10. Social networks
The Federal Government Commissioner for Migration, Refugees and Integration, who also serves as the Federal Government Commissioner for Anti-Racism (IntB), is attached to the Federal Ministry of Labor and Social Affairs (BMAS). The Commissioner performs the tasks assigned to the IntB independently in substantive matters and, in this capacity, acts as the data controller under data protection law. However, due to the Commissioner's organizational integration within the Federal Ministry of Labour and Social Affairs (BMAS), the Commissioner is also part of the BMAS and, to that extent, participates in processing activities that fall under the responsibility of the BMAS. This privacy statement provides information pursuant to Articles 13, 14, 7(3) sentence 3, and 21(4) of the General Data Protection Regulation (GDPR) and in accordance with Section 25(1) of the German Telecommunications-Telemedia Data Protection Act (TTDSG).
Data protection applies to personal data. Personal data means any information relating to an identified or identifiable natural person (known as the “data subject”). Personal data therefore includes all information which uniquely identifies a person, or via which it is possible to uniquely identify a person by combining internal and external information, such as a name, address, telephone number or e-mail address. In addition, personal data also includes information which is necessarily generated when using a website, such as the start, end and duration of the user’s session or the user’s IP address.
At the Federal Ministry of Labour and Social Affairs as well as at the IntB, personal data is processed only to the extent necessary, and it is processed primarily for the purpose of enabling the Ministry to perform public tasks and comply with legal obligations. The processing of this personal data takes place primarily on the basis of the European General Data Protection Regulation (GDPR) and the Federal Data Protection Act (Bundesdatenschutzgesetz).
This privacy notice sets out what personal data is processed, the purpose for which it is used, and the basis on which it is required and processed. Details are provided about how to contact the unit responsible and the Data Protection Officer of the Federal Ministry of Labour and Social Affairs as well as the IntB. In addition, this privacy notice includes information about the rights of data subjects and is intended, among other things, to enable them to take an informed decision on how their personal data is handled.
General reference is made to the Privacy Notice of the Federal Ministry of Labour and Social Affairs.
The following additional information is provided regarding the use of this website, publicly accessible contact options, newsletter distribution, media relations, social networks, and specific data processing activities carried out by the Federal Government Commissioner for Migration, Refugees and Integration and the Federal Government Commissioner for Anti-Racism at the Federal Ministry of Labour and Social Affairs.
1. Data controller and Data Protection Officer
- In matters for which the IntB has sole responsibility, the IntB acts as the controller for the processing of personal data and can be contacted at the following address:
- Federal Ministry of Labour and Social Affairs (BMAS)
- Federal Government Commissioner for Migration, Refugees and Integration
- Federal Government Commissioner for Anti-Racism
- Wilhelmstraße 49
- 10117 Berlin
- Deutschland
- Tel. Berlin office:
- 030 18 5270
- Tel. Bonn office:
- 0228 99 5270
- E-mail:
- poststelle@bmas.bund.de
For this area, a Data Protection Officer has been designated for the IntB. The functions of this Data Protection Officer are carried out by the Data Protection Officer of the Federal Ministry of Labour and Social Affairs (BMAS).
Datenschutzbeauftragte des Bundesministeriums für Arbeit und Soziales
- 53107 Bonn, Germany
- Tel.:
- 0228 99 5270
- E-mail:
- bds@bmas.bund.de
2. Information for data subjects under Articles 13 and 14 of the GDPR
To inform data subjects about the data processing and their rights, and to comply with the obligation to provide information (Articles 13 and 14 of the GDPR), information is provided below about individual types of processing: in section 6.
In areas where the IntBbears sole responsibility, she acts as the controller for the processing of personal data.
3. Automated decision-making
In principle, no automated decision-making takes place. If, by way of exception, automated decision-making does take place as part of a specific process, notice of this is provided in that context.
4. Transfer of data to third countries
The Ministry does not intend to transfer personal data to recipients in a third country or an international organisation. If, by way of exception, such a transfer of data does take place as part of a specific process, notice of this is provided in that context.
5. Your rights
Data subjects have rights in relation to the Federal Ministry of Labour and Social Affairs as well as the IntB, in its capacity as the data controller, when it comes to the processing of their personal data:
5.1 General rights of data subjects
Right of access (Article 15 of the GDPR)
The right of access means the data subject is entitled to receive comprehensive information about the personal data and some other important criteria, such as the purposes of the processing or the period for which the data will be kept. The exceptions to this right set out in section 34 of the Federal Data Protection Act apply.
Right to rectification (Article 16 of the GDPR)
The right to rectification enables the data subject to have inaccurate personal data corrected.
Right to erasure (Article 17 of the GDPR)
The right to erasure enables the data subject to have the controller erase data. However, this is only possible if, for example, the personal data is no longer necessary, has been unlawfully processed, or consent for the processing has been withdrawn. The exceptions to this right set out in Article 17 of the GDPR and section 35 of the Federal Data Protection Act apply.
Right to restriction of processing (Article 18 of the GDPR)
The right to restriction of processing allows the data subject to initially prevent further processing of the personal data in certain circumstances.
Right to data portability (Article 20 of the GDPR)
The right to data portability enables the data subject, in certain circumstances, to receive the personal data from the controller in a commonly used, machine-readable format so that it can potentially be transmitted to another controller. The exception to this right set out in Article 20 (3), second sentence, of the GDPR applies.
5.2 Right to object to data processing on the basis of consent
In cases where personal data is processed on the basis of consent (Article 6 (1) (a), Article 7 or Article 9 (2) (a) of the GDPR), consent may be withdrawn at any time (Article 7 (3), first sentence, of the GDPR).
The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
After consent has been withdrawn, it is possible in individual cases that, although the personal data may no longer be processed for the original purpose, processing – in whole or in part – is necessary for other reasons. The data user will be informed accordingly about this change in purpose.
Where the IntB bears sole responsibility, consent may be withdrawn by contacting the IntB using the contact details set out above. In all other cases, consent may be withdrawn by contacting the BMAS, unless the consent statement specifies a different contact point within the BMAS.
5.3 Right to object under Article 21 of the GDPR
If the processing of personal data is based on Article 6 (1) (e) of the GDPR (performance of public tasks), the data subjects have the right to object, on grounds relating to their particular situation, at any time to processing of personal data (Article 21 (1) of the GDPR). The exceptions to this right set out in Article 21 of the GDPR and section 36 of the Federal Data Protection Act apply.
The right to object may be exercised without any formal requirements, provided that the data subject's name and, where applicable, additional identifying details (e.g. email address or postal address) are supplied. Where the IntB for Integration bears sole responsibility, objections should be directed to the IntB at the address specified above. In all other cases, objections should be directed to the BMAS, unless a specific contact person or contact point within the BMAS has been indicated.
5.4 Right to lodge a complaint
Data subjects have the right to lodge a complaint about the possibility of unlawful processing of their personal data with the competent supervisory authority for data protection at the Federal Ministry of Labour and Social Affairs, namely the Federal Commissioner for Data Protection and Freedom of Information:
- Bundesbeauftragte/r für den Datenschutz und die Informationsfreiheit
- Graurheindorfer Str. 153
- 53117 Bonn
- Germany
- Tel.:
- 0228 9977990
- E-mail:
- poststelle@bfdi.bund.de
6. Website
6.1 Visiting the Website
Purpose
EEvery time a user visits the website of the IntB, the data needed to provide this service is processed. The IntB is required, on the basis of section 5 of the Act on the Federal Office for Information Security (Gesetz über das Bundesamt für Sicherheit in der Informationstechnik), to store data for the purpose of protecting the Ministry’s internet infrastructure and federal communications technology from attack. This data is analysed and is required so that legal action can be taken and a criminal prosecution can be launched in the event of attacks on communications technology.
Nature and source of the data
The following data is collected:
- Browser type and version
- Operating system used
- User’s IP address
- Server IP address and name
- Date and time of the server request
- HTTP protocol and status
- Data volume transferred
- File path
The Ministry obtains the personal data directly from the data subjects and their electronic devices.
Legal basis
The personal data is processed on the basis of Article 6 (1) (c) of the GDPR in conjunction with section 5 of the Act on the Federal Office for Information Security.
Recipients
This data is also stored in log files on a server run by the web provider Digitas GmbH, and retained after the visit to the website.
Data recorded when users visit the IntB’s website is only transferred to third parties where there is a legal obligation to do so or where this is necessary for the purpose of legal action or criminal prosecution in the event of attacks on federal communications technology. It is not transferred in any other cases.
Retention period
The data is erased as soon as the purpose of the data processing ceases to apply, unless the IntB has legitimate interests under Article 17 (3) of the GDPR or retention obligations exist on IT security grounds (in which case the retention period is three months, under section 5 (2) of the Act on the Federal Office for Information Security).
Obligation to provide data or consequences of non-provision
The website cannot be used, for functional or IT security reasons, without providing the technical connection data specified above.
6.2 Session-Cookies
Purpose
When a user orders publications using the shopping cart, the Federal Ministry of Labour and Social Affairs uses what are known as session cookies. Session cookies are small pieces of data which a service provider stores in the temporary memory of the user’s device. The session ID is used to collate the orders in the user’s shopping cart so that multiple publications can be ordered at the same time and the order can be collected in a single shopping cart.
Nature and source of the data
A session cookie contains a randomly generated unique identifier, known as a session ID. The cookie also includes information about its origin and the length of time for which it is saved. These cookies cannot store any other data.
The Ministry generates the personal data for visits to the website.
Legal basis
This takes place on the basis of Article 6 (1) (e) of the GDPR in conjunction with section 3 of the Federal Data Protection Act, so that information can be provided in line with users’ needs (see also section 25 (2) no. 2 of the Telecommunications Telemedia Data Protection Act (Telekommunikation-Telemedien-Datenschutz-Gesetz)).
Recipients
The data is not transferred to third parties.
Retention period
The session cookies set on the website of the Federal Government Commissioner for Migration, Refugees and Integration and the Federal Government Commissioner for Anti-Racism are deleted when the session is ended. If the browser window is closed or another website is loaded, the shopping cart is emptied. The items placed in it will have to be re-added if the session is ended without the order being completed.
Please note: Persistent cookies also exist, which enable visitors to be recognised even if they return to a site much later. This information is stored as a text file on the visitor’s hard drive. The website of the Federal Government Commissioner for Migration, Refugees and Integration and the Federal Government Commissioner for Anti-Racism does not use this kind of cookies.
Obligation to provide data or consequences of non-provision
Cookies can be managed using any internet browser. Most browsers are set to accept all cookies without asking the user. The browser’s settings can be changed to block or limit cookies. Cookies which have already been set can be deleted at any time. This can also take place automatically.
If the user rejects all cookies, the shopping cart cannot be used to collect multiple publications, and only one publication can be ordered at a time.
Information on how to view cookies
The data sent automatically by the browser to the Ministry’s server can be viewed in the browser’s site information.
All browsers allow users to view when cookies are set and what information they contain. The data sent automatically by the browser to the Ministry’s server can be viewed in the browser’s site information.
6.3 Web analytics
Purpose
In the context of the Ministry’s public relations activities and the tasks to be performed by the Ministry, usage information is analysed for statistical purposes so that information can be provided in line with users’ needs.
Nature and source of the data
The web analytics service “etracker” sets cookies on the visitor’s device. When individual pages of this website are accessed, the following data is stored:
- Two bytes of the IP address of the user’s device (the last six characters are anonymised),
- The page accessed,
- The page which brought the user to the page accessed (referrer),
- Recognition of returning visitors and visitor history,
- The pages visited from the page accessed,
- The time spent on the page, and
- How frequently the page is accessed.
Although the Federal Ministry of Labour and Social Affairs generates the personal data when a user visits the website, the IP address is anonymised without delay as part of this process, ensuring that users remain anonymous from the Ministry’s perspective.
The software is set not to store IP addresses in full; instead, two bytes of the IP address are masked (e.g. 192.168.xxx.xxx). This means the truncated IP address can no longer be attributed to the accessing device.
Legal basis
This anonymisation of personal data is carried out on the basis of Article 6(1)(c) in conjunction with Article 5(1)(c) of the GDPR (principle of data minimisation).
The temporary collection of the IP address prior to anonymisation is carried out on the basis of Article 6(1)(a) and Article 7 of the GDPR and, in all other respects, in accordance with Section 25(1) of the TTDSG. A decision regarding the collection can be made in advance. This is done via the selection that users make in the cookie notice at the start of their visit. If users wish to change their selection at a later date, they can do so by clicking on the link below. The cookie dialogue will then open again and the settings can be changed accordingly
Recipients
The software runs solely on the servers of the “etracker” service provider on behalf of the IntB. Usage information is only stored there. The data is not transferred to third parties.
Retention period
As part of this process, the IP address is anonymised without delay, ensuring that users remain anonymous from the IntB’s perspective.
Obligation to provide data or consequences of non-provision
If users have not given their consent for the storage and analysis of this data relating to their visit, an opt-out cookie is set in their browser, which stops “etracker” from collecting any session data.
Users can decide here whether to give consent for a unique web analytics cookie to be set in their browser to enable the website’s operator to collect and analyse various types of statistical data.
If you do not wish to give consent for this, please click the following link to set the “etracker” opt-out cookie in your browser.
Please note: Clearing cookies will also delete the opt-out cookie and it may then need to be activated again by the user.
7. Contacting the Commissioner via publicly accessible contact options
Purpose
The personal data provided when an individual contacts the IntB is processed for the purpose of handling, responding to and documenting the communication.
The IntB can be contacted via the IT and communication services and applications of the BMAS as follows
- The contact form
- The e-mail addresses intb[at]bmas.bund.de
- The e-mail addresses presse-integration.intb[at]bmas.bund.de
- Letters can be sent to the Commissioner’s postal address
- Telephone
Nature and source of the data
The data submitted in connection with these concerns are processed as follows, in accordance with the processing described in the BMAS privacy statement.. When individuals contact the IntB, they have to provide their postal address, as the IntB is required by the Joint Rules of Procedure of the Federal Ministries (Gemeinsame Geschäftsordnung der Bundesministerien) to respond to communications from members of the public by post, and sending the reply by post is often the only way to guarantee it is confidential.
Other information contained in the communication, together with any enclosures or attachments, which may be necessary for handling it can include the number of years worked (in the case of pension queries). Additional information can include data concerning health, information relating to trade union membership, and so on.
The IntB usually receives the personal data directly from the data subjects when they contact the IntB; it may also receive personal data from agencies in its area of responsibility in cases where they are involved in examining and responding to the communication.
Legal basis
The processing of the identification and address data and the personal data necessary for handling the communication takes place on the basis of Article 6 (1) (e) of the GDPR in conjunction with section 3 of the Federal Data Protection Act. Any further information is processed on the basis of consent under Article 6 (1) (a) in conjunction with section 7 of the GDPR.
Where the communication or the enclosures or attachments contain special categories of personal data (such as data concerning health or trade union membership), this information is provided voluntarily and the IntB regards the provision of this data as consent for it to be processed as well under Article 9 (2) (a) of the GDPR. Where the processing of this particularly sensitive data takes place on the basis of consent, the data subject’s attention is explicitly drawn to the right to withdraw consent under Article 7 (3) of the GDPR.
Recipients
Communications sent via the contact form:
Communications sent via the contact form on the website of the IntB are processed by the IntB's office and citizens' service.
In connection with the processing and examination of the facts by the IntB’s staff, it may be necessary to pass on the matter to agencies within the IntB’s area of responsibility or other competent agencies so that a technically sound or informed response can be provided.
Under Article 6 (1) (e) of the GDPR in conjunction with sections 3, 25 and 23 of the Federal Data Protection Act, the transfer of data takes place only if it is in the interest of the data subject and the communication does not contain any indication that the data subject does not agree to the involvement of such agencies.
In most cases, these agencies within the IntB’s area of responsibility or other competent agencies or another federal ministry (for example the Federal Ministry of Health in the case of questions relating to medicines, or the Federal Ministry of Finance in the case of questions relating to taxes).
If there is any indication that the data subject may not want the data to be transferred, the IntB will seek the data subject’s prior consent. The same applies if the documents contain special categories of personal data (Article 9 of the GDPR, e.g. data concerning health) which must be passed on for examination.
Retention period
The data retention periods are determined in accordance with the Administrative Regulation for Payments, Bookkeeping and Accounting (VV-ZBR BHO 4.7 and no. 6 of Annex 1), the General Administrative Regulation on Physical Security issued by the Federal Ministry of the Interior (VS-Anweisung), and the guidance issued by the Federal Archives on records management regarding the setting of retention periods for the records of supreme federal authorities in accordance with section 19 of the Directive on the Processing and Management of Records in Federal Ministries (Registraturrichtlinie).
Where the communication is received in the context of a submission from an individual, for example, the retention period begins at the end of the calendar year in which the processing was completed and is one year until December 31, 2023 and five years from January 1, 2024. The retention period is up to 20 years in the case of technical subjects or opinions, and up to 30 years for opinions submitted in the framework of the legislative process; in each case, this period begins at the end of the calendar year in which the processing was completed.
Please note: The IntB may destroy documents which are not required.
8. Newsletters
Purpose
In this context, the IntB uses personal data solely to send the newsletters on all topics related to the IntB and for statistical analysis of the system’s performance.
Nature and source of the data
Anyone who wishes to sign up for one of newsletters of the IntB, needs to provide their email address and specify the newsletter(s). The IntB receives the personal data directly from the data subjects.
Legal basis
The data is processed on the basis of consent under Article 6 (1) (a) of the GDPR.
The sign-up system uses a double opt-in approach, sending an additional confirmation e-mail containing a link for final registration; this ensures that the person signing up for the newsletter definitely wishes to receive it.
Upon registration, the data is stored on the Ministry’s server and a confirmation e-mail containing a link for final registration is sent to the e‑mail address provided. If the registration is not confirmed via the link in this e-mail, the data is erased after 24 hours.
The newsletter-related data is only stored for use in connection with the newsletter service once registration has been confirmed via the link in the e-mail.
Recipients
This personal data is stored on a Ministry server.
Newsletter sign-ups are managed by the service provider Digitas GmbH. Beyond that, the data is not transferred to third parties.
Retention period
Subscribers who no longer agree to their data being stored for this purpose, and thus no longer want to use the IntB’s newsletter service, can withdraw their consent to data processing for the purpose of sending the newsletter at any time.
They will then be unsubscribed from the newsletter and the data provided is erased.
Here you can unsubscribe to the newsletter. You will need to provide the e-mail address you gave when signing up for the newsletter.
Obligation to provide data or consequences of non-provision
The chosen newsletter cannot be sent without the subscriber’s e-mail address.
9. Media relations
Press mailing lists
Purpose
The personal data is processed to facilitate the provision of information relevant for the press which has been requested by media representatives (press releases, invitations to events open to the press, and similar information). The office of the Federal Government Commissioner for Migration, Refugees and Integration and the Federal Government Commissioner for Anti-Racism also uses the stored data so that it can contact media representatives as part of its wider media relations work (e.g. inviting representatives to press events or arranging interviews).
Nature and source of the data
The following personal data is processed:
- Surname, given name
- Media outlet
- E-mail address (usually the business e-mail address)
- Telephone number (usually the business number)
When an individual is added to certain mailing lists set up by the office of the Federal Government Commissioner for Migration, Refugees and Integration and the Federal Government Commissioner for Anti-Racism (e.g. the background mailing list), the address of the editorial office/publishing company is also requested.
The office of the Federal Government Commissioner for Migration, Refugees and Integration and the Federal Government Commissioner for Anti-Racism obtains personal data (independently, upon request) directly from the respective journalists and/or directly from their editorial offices. For entries in the press distribution list, publicly available sources (e.g., the membership directory of the Bundespressekonferenz e.V.) are also used.
Legal basis
The data is processed on the basis of Article 6 (1) (e) of the GDPR in conjunction with section 3 of the Federal Data Protection Act.
Recipients
The data is not transferred unless the individual media representatives explicitly give prior consent to the transfer of data.
Retention period
The personal data is retained by the Press Division until consent is withdrawn. In addition, this data is erased if it becomes known that a journalist is leaving or is no longer covering the issues falling within the Commissioner’s area of responsibility. The data is also erased if, for example, the recipient can no longer be reached for technical reasons.
All of the Commissioner’s messages sent to the media contain a note indicating that the recipients can, at any time, make use of their right to object to processing and to obtain the erasure of their personal data from the mailing lists managed by the Commissioner’s press office. It is sufficient to simply send an e-mail to presse-integration.intb(at)bmas.bund.de.
Obligation to provide data or consequences of non-provision
The provision of personal data is necessary so that messages can be sent to the media. Without this data, information relevant for the press (e.g. press releases, press invitations and similar information) cannot be sent to media representatives and their editorial offices.
Media enquiries
Purpose
The press office of the IntB answers journalists’ enquiries by telephone and in writing. For this purpose, and for the purpose of documentation, it is necessary to collect personal data from the journalists submitting the enquiries.
Nature and source of the data
The following data is collected and processed:
- Surname, given name
- Media outlet
- E-mail address
- Telephone number
All data which the journalists include in their email signature and thus actively make available to the office of the IntB when submitting written enquiries.
Where necessary, journalists can be asked to present a copy of their press card.
The office of the IntB receives the personal data solely from the journalists direct in the framework of their enquiries.
Legal basis
The data is processed on the basis of Article 6 (1) (e) of the GDPR in conjunction with section 3 of the Federal Data Protection Act.
Recipients
Where necessary, the press office consults external third parties in order to answer the enquiry, including, for example, the Federal Employment Agency, pension insurance funds, and other ministries. No particularly sensitive data (Article 9 of the GDPR) is transferred to other organisations unless the media representatives concerned or the data subjects explicitly give prior consent to the transfer of data.
It is necessary to pass on the personal data together with the enquiry in order to check whether similar enquiries have already been received in the past from the media representatives in question, and because the nature and scope of the answer can depend on the individual/outlet submitting the enquiry.
Retention period
Incoming media enquiries in electronic and analogue form, and those received by telephone and documented by the office of the IntB, are stored in accordance with the retention periods for records established by the Directive on the Processing and Management of Records in Federal Ministries (Registraturrichtlinie), which supplements the Joint Rules of Procedure of the Federal Ministries (Gemeinsame Geschäftsordnung der Bundesministerien). The retention period is usually ten years from the end of the calendar year in which the response was completed..
Obligation to provide data or consequences of non-provision
Enquiries from journalists cannot be answered unless basic personal data is provided.
The Commissioner’s press office only answers enquiries from journalists. Journalists may be required to present their press card so that the press office can check that the enquiry is legitimate.
9. Press events
Purpose
To carry out its public tasks, the office of the IntB regularly holds press events (press conferences, background discussions, etc.) with journalists. Personal data is processed for the purpose of attendee management.
Nature and source of the data
The following personal data is processed:
- Surname, given name
- Media outlet
- E-mail address (usually the business e-mail address)
- Telephone number (usually the business number)
The data of the journalists invited is usually already contained in the press office’s mailing lists, as it is already needed so the invitations can be sent to the relevant recipients.
In a media outlet’s day-to-day work, invitations are sometimes passed on to journalists on duty, who attend any press events on a stand-in basis. The personal data which the office of the IntB obtains in connection with the registration of the journalists attending on a stand-in basis is not stored automatically. In these cases, too, the data is only stored at the explicit request of the journalists in question.
The attendance lists required by the coronavirus ordinances are filled out by attendees on arrival at press events. Personal contact details may also have to be provided in this context.
Legal basis
The data is processed on the basis of Article 6 (1) (e) of the GDPR in conjunction with section 3 of the Federal Data Protection Act.
Recipients
The service providers who have been tasked by the Federal Ministry of Labour and Social Affairs or the IntB with carrying out screening at the entrances have access to the data of the registered journalists.
Obligation to provide data or consequences of non-provision
The provision of the personal data is necessary for the planning and organisation of the press event in question, and for journalists to be given access to the IntB’s buildings.
10. Social networks
Public relations activities via social networks constitute data processing in the public interest. The Federal Constitutional Court ruled in 1977 that the Federal Government’s public relations activities are not just constitutionally permissible, but also necessary, as democratic decisions require an informed public. The Court affirmed this in another ruling in 1983, provided that the government communicates its policies objectively, accurately, proportionately and with restraint. Other judgments came to the same conclusion.
Statistical studies show that the way the public consumes media and seeks information is changing. A growing number of population groups obtain less and less information about current affairs from “traditional” information channels, such as newspapers or television channels. Instead, they obtain information from media that operate solely or at least partly online, and above all from social networks. One of the aims pursued by the IntB in her/his public relations activities is reaching as many population groups as possible and informing them in the framework of its constitutional remit.
The IntB therefore uses social networks, alongside other essential media channels. This gives the public a range of channels, all upholding the same quality standards, via which they can obtain information about the Ministry’s work and get in touch with the Ministry.
Alternatively, the information offered via these services can also be accessed on the Commissioner’s website.
Guidance (in German) on privacy-enhancing user settings on social networks can be accessed on the website of the Federation of German Consumer Organisations at: https://www.verbraucherzentrale.de/wissen/digitale-welt/soziale-netzwerke. Further information (in German) on social networks and how personal data can be protected can also be found on the website of the Federal Office for Information Security (BSI) and at www.youngdata.de.
Purpose
The IntB is active on Instagram.
The operation of the IntB’s social media profile is necessary for targeted and balanced public relations activities, personnel recruitment, and the Federal Government’s crisis communication.
In order to perform its tasks on the social networks, the editorial team processes the data of people who actively engage with the IntB there, for example via comments or messages. The personal data provided also has to be processed for the purpose of reacting to individual communications.
- Nature and source of the data
The data can consist of profile information (such as name, profile picture, number of followers and number of profiles followed by the data subject), comments, posts, reactions, direct messages, the content of enquiries, and most recent tweets.
The office of the IntB obtains the personal data directly from the data subjects and their electronic devices. At most, the office of the Commissioner receives anonymised statistical data from the social networks’ services.
Legal basis
The data is processed on the basis of Article 6 (1) (e) of the GDPR in conjunction with section 3 of the Federal Data Protection Act.
Recipients (potentially in third countries)
We expressly draw attention to the fact that social networks also store and process their users’ data. Even if this data processing constitutes an arrangement involving joint controllers under Article 26 of the GDPR, these social networks remain contracting parties and points of contact for users on data protection issues.
X
The IntB uses the technical platform and services of X Corp.,1355 Market Street, Suite 900, San Francisco, CA 94103, United States.
Information about what data is processed by X and for what purposes it is used can be found in X’s privacy policy. Users also have the option of requesting information via the X privacy policy inquiries form (https://help.x.com/en/forms/privacy) or by downloading their X archive (https://help.x.com/en/managing-your-account/how-to-download-your-x-archive).
The IntB draws attention to the fact that users are responsible for their use of the X service and its features. This is particularly true of the interactive features (e.g. retweets, likes). Users should give careful consideration to what personal data they share with the IntB via X.
The IntB has no influence over the nature and scope of the data processed by X, the work of processing and using this data, or the transfer of this data to third parties.
The data about users collected in the course of using the service is processed by X Corp. and, in this context, it may be transferred to countries outside the European Union. This data includes the IP address, the app used, information about devices used (including device ID and app ID), information about webpages visited, location and mobile provider. This data is associated with the data of the X account or profile in question.
Information about what data is processed by X and for what purposes it is used can be found in X’s privacy policy: https://x.com/privacy?lang=en; information is also available about ways for users to access their own X data: https://help.x.com/en/managing-your-account/accessing-your-x-data.
X buttons or widgets embedded on websites and the use of cookies enable X to track visits to these sites and attribute them to the X profile in question. This data can be used to serve tailored content or ads. Information about this and the settings available can be found on the following X support pages:
https://help.x.com/en/safety-and-security/privacy-controls-for-tailored-ads
https://help.x.com/en/rules-and-policies/x-cookies
There are options to limit the processing of personal data in the general settings of a X account, as well as under the “Privacy and safety” heading. In addition, mobile devices (smartphones, tablets) have settings which can be used to restrict X’s access to contact and calendar data, photos, location data, etc. This depends on the operating system, however. Further information on these issues can be found on the following X support page: https://support.twitter.com/articles/105576#
Guidance (in German) on privacy-enhancing user settings can be accessed on the website of the Federation of German Consumer Organisations at: https://www.verbraucherzentrale.de/wissen/digitale-welt/soziale-netzwerke
Information can also be requested via Google’s privacy policy form.
Instagram
The IntB uses the Instagram service. Instagram is an online service for sharing photos and videos, and is owned by Meta, formerly Facebook. To provide its information service on this platform, the IntB uses the technical platform and services of Meta Platforms Ireland Ltd., Merrion Road, Dublin 4, D04 X2K5, , Ireland.
The IntB draws attention to the fact that users are responsible for their use of the Instagram service and its features. This is particularly true of the interactive features (e.g. sharing, liking). Users should give careful consideration to what personal data they share via the IntB’s Instagram page.
Information about what data is processed by Instagram and for what purposes this data is used can be found in Instagrams's Data Policy. Die vollständigen Datenrichtlinien des Dienstes Instagram sind hier zu finden: https://help.instagram.com/581066165581870/?helpref=hc_fnav.
When users visit the IntB’s Instagram page, Meta records, among other things, IP addresses and other information from cookies stored on the user’s device. This information is used to provide the IntB, as the admin of the Instagram page, with anonymised statistical information about the use of the Instagram page. The Data Policy is available at the following link: https://help.instagram.com/519522125107875 . The full Terms of Use of the Instagram service can be found here: https://help.instagram.com/581066165581870/?helpref=hc_fnav.
Meta provides information about the use of cookies in the Cookies Policy for the Instagram service: https://help.instagram.com/1896641480634370/?helpref=hc_fnav.
The IntB draws attention to the fact that the cookies used enable Meta Platforms Ireland to track user behaviour (across devices, in the case of logged-in users) even beyond the Instagram service, on other websites. This applies to data subjects irrespective of whether or not they are registered with the Instagram service.
Meta itself states that it stores data until it is no longer necessary to provide its services and Meta products, or until the user’s account is deleted, whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. More detailed information about data retention can be found at: https://facebook.com/about/privacy.
Meta processes a variety of personal data about page visitors for its own purposes in the framework of what it calls “Insights”. This processing takes place irrespective of whether or not page visitors are logged into Facebook or Instagram, and whether or not they have a Meta or Instagram account. Users who visit Instagram pages without being registered with or logged into Instagram still have the option to influence the scope of data processing via the cookie banner shown by Meta. More detailed information about Meta cookies can be found at: https://www.facebook.com/policies/cookies/
Instagram Insights are aggregated, anonymised statistics. Page admins do not have access to the personal data processed in this context but only to the aggregated, anonymised Insights. More detailed information can be found at: https://www.facebook.com/help/instagram/788388387972460
Meta Platforms Ireland is required to respond to requests from data subjects. Meta provides further information about the rights of data subjects here: https://www.facebook.com/help/2069235856423257
Requests from users relating to data processing when visiting an Instagram page which fall within the sole responsibility of Meta Ireland are forwarded to Meta Platforms Ireland by the Federal Ministry of Labour and Social Affairs. Users can contact Meta’s Data Protection Officer themselves at the following link: https://www.facebook.com/help/contact/540977946302970
Meta also provides information about privacy-enhancing profile settings for Instagram profiles: https://help.instagram.com/811572406418223/?helpref=hc_fnav
Retention period
The personal data will be erased, to the extent that this is within the IntB’s power, when the IntB stops offering information services on these social network sites. If this data is retained beyond this point by the individual social network services, this is based solely on the provisions in their data policies and terms of use.
Obligation to provide data or consequences of non-provision
There is no obligation to provide this data.
Members of the public who use these platforms to submit requests to the IntB are notified that individual personal requests are only processed and answered with reference to the individual case via the IntB’s usual contact methods.