VICO Research & Consulting GmbH is the German market leader in the development of individual social media monitoring systems. VICO also has a full-service agency for social media development - starting with market research on monitoring, to consulting and concrete implementation of social media skills and actions. With special tools and analysis methods, VICO helps make the consumer generated content on the social web transparent, detectable and usable.
Right from its foundation VICO has always had respect for the privacy rights of all parties involved in the social web as based on the requirements of European and especially German data protection legislation. VICO hired a data protection officer early on, and makes constant efforts to comply with statutory requirements.
- What personal information VICO processes and for what purposes
- How VICO processes this personal data
- On what legal basis VICO processes this information and to whom VICO makes the data available
- What VICO does to protect personal data
- Which supervisory authority is responsible for VICO
- What VICO is doing to safeguard the rights of persons affected
For what purposes VICO processes personal data and what does this personal data consist of?
As a full service agency for social media, analysis of publicly available content in social media is the core service of the company. The contents include Facebook, Google+, blogs, forums, Qype, Twitter, the commercial register, e-Federal Gazette or other websites. Depending on the order, it may also be important to identify opinion leaders on specific topics. It is crucial that VICO uses only publicly available content that has been made freely available to the public by the respective users. Non-public areas such as forums, which are subject to a closed circle, are not analyzed by VICO or are integrated only after permission is outdated. VICO heeds and respects the privacy of the users and adheres to the legal requirements. For the analysis of publicly available content VICO is a social media monitoring tool that works much like a search engine. It can examine public sources as far as related search terms can be entered. Searches can in principle be of all theoretically possible search terms. However VICO is aware of its social responsibility, and disclaims principle orders from violating its moral, legal and ethical values, in particular projects that infringe heavily on the personal rights of people.
How does VICO process personal information?
The search terms are usually specified by VICO's client. Current search topics include, for example, brand names, product names, companies, events, etc. These are usually not personal search topics.Based on the search topic, the next step will be to record author names or pseudonyms for posts, texts, URLs and dates. Thus, personal data could and will be collected, for example if an author publishes under their real name. At this time, no further personal data will be extracted from the captured text.At the analysis stage, the texts are classified either by search algorithms or are manually read by VICO employees or the client. Typical classifications are texts on service topics, problems with products, complaints, satisfaction with products or brands, tonality, PR issues, marketing campaigns, language and / or interests such as certain hobbies (environment, leisure, consumption, labour). Using the social media monitoring tool, it can be determined which authors have written most about these topics. It can also be filtered by authors' individual contributions.In the last step reports on the search results are generated. In the preparation of the reports VICO's staff ensure that any personal references are removed that might violate the legitimate interests of authors concerned. Our staff are sensitive, and proceed strictly in accordance with work instructions. This ensures that no individuals can be identified in the reports.VICO also offers their clients pseudonymisation of data on request, so that personal references are dispensed with and personal rights of those affected are protected. In this way, any reference to individuals can be avoided even in the collection of data, so that it no longer exists when the client recieves the data.During the use of social media monitoring tools by users, protocol for the use and optimisation of the tool will be followed. Logging is done on an anonymous basis.
What is the legal basis for VICO's social media monitoring tool and who provides VICO with this data?
For VICO there are two different settings:In the first case VICO is often active in the context of processing data in accordance with § 11 of the Federal Data Protection Act (BDSG) for their clients. This means that the VICO client gives an exactly formulated mandate for data collection on the social web. Thus it is defined, in which social web elements VICO may collect (see previous paragraph), store and transmit the data to the client. In addition, the obligations between the client and VICO are clearly defined, for example, when data should finally be deleted, which measures to protect personal data are in use, etc. In addition to these first data protection checks, inspection is carried out for the client by VICO and the data protection officer, a second independent check of whether all the contents of the contract are compliant with the Federal Data Protection Act. Only after this double control of data protection has been carried out does VICO start the social media monitoring. In the second case VICO is also mandated to carry out social media monitoring of the activities of entities. These are monitoring activities without respect to an individual and to no order of data processing according to § 11 BDSG. The central legal basis for VICO here is § 29 para. 1, no. 2 BDSG. This allows VICO the use of publicly available information, as long as it outweighs any legitimate interests of stakeholders. If VICO applies the search topics for the client, there is a careful balance between the interests of the client and VICO and the legitimate interests of the data subject. This will be considered particularly if issues such as information on racial and ethnic origin, political opinion, religion, religious or philosophical beliefs, trade union membership, health, sexual life or individualized personality profiles are to be collected. Since explicit consent is required for passing of this particularly sensitive data, if necessary, the disclosure of aggregated non-personal information must take place. A transfer of personal data to other entities outside of VICO can be done when this is based on administrative orders, such as for the investigation of criminal offenses, for solving technical problems of when there are legal requirements.
What efforts does VICO undertake for the protection of personal data?
VICO has taken many technical and organisational precautions to ensure the protection of personal data at all times. As for risk analysis, potential risks are assessed and then dealt with. A data protection concept for the organisation ensures a holistic implementation of data security and privacy. All relevant processes for social media monitoring have been reviewed and extensively documented with written procedures under § 4e BDSG, and any premises in which processing of personal data takes place were checked for data protection risks.Customer data is stored in a secure data centre with a variety of measures. Other measures beyond those legally required, such as access, entry, sharing, dissemination, intake, briefing and availability controls, as well as the principle of separation, are implemented. These include for example measures such as user rules, access rules, data security measures, staff training, security measures for data processing systems, use of firewalls, building security measures, use of encrypted data transmissions, extinguishing requirements etc. These measures are regularly inspected, assessed and if necessary improved.
Which supervisory authority is responsible for VICO?
The supervisory authority responsible for data protection for us is the regional data protection officer in Baden-Württemberg.
What does VICO do to safeguard the data subjects' rights?
Of course VICO ensures the legally guaranteed rights affected. If VICO is responsible for the data processing, VICO shares on demand in writing whether and which personal data is stored in this case. VICO will be happy to rectify personal data. Under certain conditions, a stoppage or deletion of stored personal data is possible, provided that no statutory retention periods exist. This is to be proved in each case. In the case of order data processing, data protection responsibility lies with the customers, so it is possible that VICO will refer to the agency contact for a response to requests, as VICO cannot answer these questions.
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VICO Research & Consulting GmbH