Record of Data Processing Activities

Data Controller

Alexander Raschke
Institut für Softwaretechnik und Programmiersprachen
Fakultät für Ingenieurwissenschaften, Informatik und Psychologie
E-Mail: alexander.raschke(at)uni-ulm.de
Universität Ulm
89069 Ulm

Data Protection Officer

Irina Weiß
Datenschutzbeauftragte der Universität Ulm
Deutsche Datenschutzkanzlei
E-Mail: dsb(at)uni-ulm.de
Phone: +49 (7542) 9492109

Note

Currently phone number links are not supported. Will be supported in version 3.3.0.

A link for a telefon number will then look like: `+49 (7542) 9492109<tel:+4975429492109>`__

Data subjects

Users

An user is a person who used any feature of the app. The targeted users are students, employees and guests of the Ulm University.

Developers

A developer contributed to the project. Up to now, that are mainly Software Engineering students and our supervisor Alexander Raschke. External contributions such as the contributions from the Studierendenwerk are not treated as contributions by a developer.

Data categories

We try to predefine all data categories beforehand. As a result, we try to achieve a high level of transparency to the user.

Personal Contact Data

Personal contact data can be:

Full Name
email address
phone number

Personal Preferences and Interests

This kind of data refers to news articles and events. User’s interests and preferences may be identified through their ratings.

Data Protection Impact Assessment

A data protection impact assessment (DPIA) has not been conducted yet. Furthermore, we assume that an DPIA might be necessary before the release of the application, because of the feature to like and dislike newsletters in combination with the personal data like name, e-mail and address which is required to use the Bulletin Board.

In case a DPIA is required, the data controller or the students who conduct the DPIA must contact the data protection officer for advice (Article 35 (2) GDPR | Goto German translation).

Data Processing Activities

Processing activity name	Recording date of last activity
Related Features	Bulletin Board, News, Events, FAQ
Data subjects categories	Users
Data categories	Personal Data
Lawful basis	Terms of Use
Purpose	Erasure of inactive accounts
Data retention period	4 months after inactivity
Data controller	Alexander Raschke
Processing activity details	The erasure concept foresees an automatic removal of accounts that exceed the expiration period. To determine inactive accounts, we update the user accounts property `last_seen` every time a user requests the API using a pseudonymized method. That means, the UUID of the device is transmitted in the request. The system uses a scheduled job to remove all user accounts where the difference between current date and the `last_seen` date exceeds the expiration period.
Data processor	Only internal processing
Data receiver	Only internal processing
Security measures	SSL Encryption of communication channels
External systems	Sentry (Debugging)
Owner name	Alexander Raschke

Processing activity name	Processing and Publishing of Adverts by Users
Related Features	Bulletin Board
Data subjects categories	Users
Data categories	Personal Contact Data
Lawful basis	Terms of Use
Purpose	Accountability in case of misconduct towards authorities
Data retention period	4 months after inactivity
Data controller	Alexander Raschke
Processing activity details	We provide authentication using the university e-mail addresses. The authentication MUST be successfully completed before an user’s adverts are published to other users. As a consequence, we are able to identify every user that publishes adverts on our platform. Thus, we are able to support the authorities when a user misconducts on our platform, e.g. by providing illegal adverts.
Data processor	Only internal processing
Data receiver	Only internal processing
Security measures	SSL Encryption of communication channels
External systems	Sentry (Debugging)
Owner name	Alexander Raschke

Processing activity name	Processing of geolocations identified by room locations
Related Features	Campus Map
Data subjects categories
Data categories
Lawful basis	Terms of Use
Purpose	Navigation or Positioning of a user
Data retention period	not stored
Data controller	Alexander Raschke
Processing activity details	Geolocations encoded in room numbers will be used to determine the position of a user. To the system, the user is unknown. The geolocation is used to generate a route path for the user to his or her destination. It is likely that individual routes might be cached in future to speed up the system. As a consequence, the route will be stored independently from a user. Thus, the user is still anonymous.
Data processor	Only internal processing
Data receiver	Only internal processing
Security measures	SSL Encryption for connection, anonymized processing of geolocations
External systems	Sentry (Debugging)
Owner name	Alexander Raschke

Processing activity name	Rating Articles (News & Events, FAQ)
Related Features	News & Events, FAQ
Data subjects categories	User
Data categories	Personal Preferences and Interests
Lawful basis	Terms of Use
Purpose	Estimating relevancy of events, news or FAQs
Data retention period	4 months
Data controller	Alexander Raschke
Processing activity details	The relevancy of articles will be determined based on user ratings. Especially in case of FAQ, the ratings are used to estimate more important or more frequent questions.
Data processor	Only internal processing
Data receiver	Only internal processing
Security measures	SSL encryption, only aggregation operations on data, pseudonymization
External systems	Sentry (Debugging)
Owner name	Alexander Raschke

Processing activity name	Processing feedback of users
Related Features	Feedback
Data subjects categories	Users
Data categories	Device information, Personal Contact Data
Lawful basis	Terms of Use
Purpose	Analyze feedback to improve the application and receive new ideas.
Data retention period	4 months
Data controller	Alexander Raschke
Processing activity details	User feedback is only stored in the database at the moment. Further processing can only be done manually.
Data processor	Only internal processing, Developers, Product Owner
Data receiver	Developers
Security measures	SSL encryption
External systems	Sentry (Debugging)
Owner name	Alexander Raschke

Processing activity name	Rating and preferencing of food
Related Features	Canteens
Data subjects categories	Users
Data categories	Personal Preferences and Interests
Lawful basis	Terms of Use
Purpose	Rating food for feedback and recommendation
Data retention period	4 months
Data controller	Alexander Raschke
Processing activity details	A food rating will be calculated from the ratings of all users. The rating shall help users to choose their favorite food. Furthermore, the feedback might be forwarded to the Studierendenwerk Ulm to help them to improve. The letter is not implemented yet. Furthermore, the mealplan can be filtered and favorits can be chosen. Therefore, the preferences are processed locally on the user’s device.
Data processor	Only internal processing
Data receiver	Only internal processing, (Studierendenwerk Ulm)
Security measures	Client-based processing of preferences, data minimization
External systems	Sentry (Debugging)
Owner name	Alexander Raschke

Processing activity name	Publishing and Authorship
Data subjects categories	Developers
Data categories	Personal Contact Data
Lawful basis	Authorship, Copyright
Purpose	Crediting developers and authorship
Data retention period	None
Data controller	Alexander Raschke
Processing activity details	The developers and authors are documented in Gitlab, the public website, and in the Sphinx documentation. This is how we want to credit their efforts and to document the history of the application.
Data processor	Only internal processing
Data receiver	Public (Websites), Developers/Restricted Access (Gitlab)
Security measures	None
External systems	Sentry (Debugging)
Owner name	Alexander Raschke

Data Transfer

User-related data will not be forwarded to other countries. Instead, user data is processed on our own servers which are located in Germany. At the moment we only forward bus stop names to the API of the SWU to provide real time traffic data to our users. In future, we might forward feedback about meals to the Studierendenwerk Ulm. We do not forward any other data at the moment.