Privacy policy

For electronic applications in the Social housing eligibility certificate (WBS) procedure on the social platform

Privacy policy for electronic applications in the Social housing eligibility certificate (WBS) procedure on the social platform

In this privacy policy for the social platform, which can be accessed at https://sozialplattform.de, we explain below how information that can be individually assigned to you or others as a person (the "personal data") is processed and used on the social platform.

We explain for each step of data processing,

which authority is responsible for data protection (see section 1),
whom you can contact if you have any questions about data protection (see section 2), and
what rights you and other persons whose personal data is processed are entitled to (see section 3).

We then explain the individual steps of data processing in section 4, in particular why these steps are carried out in each case, the legal basis on which they are based, how the steps work in each case and how the personal data is specifically processed in each case.

1. Responsible authority

For the processing of personal data in the context of the electronic application, the authority responsible under data protection law is the one that is also responsible for the further processing of the application in the subsequent administrative procedure or to which the application is sent electronically.

The authority responsible under data protection law for the specific application is displayed on the service details page after selecting the location.

For inquiries regarding data protection, the data protection officer of the respective authority should be contacted directly. The contact details are listed in section 2.

2. Data protection officer, supervisory authority

The contact details of the data protection officer of the authority responsible for data protection depend on your place of residence. You will be informed as follows when your personal data is collected: As soon as you have selected an application and your place of residence, you will be taken to the selected application route by clicking on "Submit application". Here you select a registration method, e.g. BundID. Once you have made your selection, you will be taken to the terms of use and data protection information. If you click on "Privacy policy", you will find the contact details of the data protection officer under point 9.

3. Rights as a data subject

Any person whose personal data is processed by a public authority can exercise the following rights as a data subject vis-à-vis the responsible authority (see section 1).

3.1. Right of access and copy

Affected persons may request information from the authority pursuant to Art. 15 GDPR as to whether it processes personal data concerning them. If this is the case, data subjects can request the information on data processing specified in Art. 15 GDPR. At the request of the data subject, the responsible authority (in accordance with section 1) shall provide a copy of the personal data processed.

3.2. Right to rectification

Data subjects may request that the authority rectify inaccurate personal data concerning them or, where applicable, complete incomplete personal data in accordance with Art. 16 GDPR.

3.3. Right to erasure

Data subjects may request the authority to erase personal data concerning them in accordance with Art. 17 GDPR, provided that the conditions set out in Art. 17 GDPR are met.

3.4 Right to data portability

Data subjects may request that the authority provide them with the personal data concerning them in a structured, commonly used and machine-readable format in accordance with Art. 20 GDPR. They have the right to transmit this data to another controller. This only applies if the processing is based on consent or if the processing is carried out by automated means.

3.5. Right to restriction of processing

Data subjects may request the authority to restrict the processing of personal data concerning them in accordance with Art. 18 GDPR, provided that the conditions set out in Art. 18 GDPR are met.

3.6. Right to object to processing

Data subjects may, on grounds relating to their particular situation, lodge an objection with the authority pursuant to Art. 21 GDPR to the processing of personal data concerning them which is carried out on the legal basis of Art. 6 para. 1 subpara. 1 lit. e) GDPR.

The authority will then no longer process the personal data unless it can demonstrate and, where applicable, prove that the conditions for continuing the processing of this data are met.

3.7. Right to withdraw consent

Affected persons may at any time withdraw consent that they have given to the authority for the processing of personal data concerning them in accordance with Art. 7 para. 3 GDPR. The withdrawal of consent is only effective for the future; the processing of personal data already carried out on the basis of the consent is not affected by the withdrawal.

If consent is only given for a single processing step, this processing step is carried out and completed immediately after consent is given, and subsequent processing steps are not carried out on the basis of consent, any withdrawal of consent may no longer have any effect.

3.8. Right to lodge a complaint with the data protection supervisory authority

Affected persons may lodge a complaint about the processing of personal data concerning them by the authority at any time. Such a complaint must be lodged with the competent data protection supervisory authority.

4. How your personal data is processed

In this section 4, we explain the individual processing steps in which personal data is processed. We describe the general and overarching processing steps (sections 4.1 and 4.3) and in section 4.2 we discuss the application that can be submitted electronically via the social platform for a residence entitlement certificate.

4.1. Technical operation of the social platform

The technical operation of the social platform, and therefore all processing of personal data in accordance with this privacy policy, is carried out entirely by Landesbetrieb Information und Technik Nordrhein-Westfalen (IT.NRW), Mauerstraße 51, 40476 Düsseldorf. IT.NRW acts as an additional processor for the authority responsible for data protection (see section 1 above) in accordance with Art. 28 GDPR.

4.2. Electronic applications for benefits

In the following, we present the application in detail.

Social housing eligibility certificate (WBS) in North Rhine-Westphalia

Whose personal data is processed? (Categories of data subjects)

Applicants, including, for example, representatives or caregivers

Beneficiaries

Household members of the beneficiaries

Which categories of personal data are processed?

Applicant: capacity as beneficiary, representative or carer.
All categories of data subjects:
Contact details: First name; surname; maiden name; date of birth; place of birth; country of birth; street; house number; address suffix; zip code; city; telephone number; e-mail address; nationality; permanent residence in Germany.
Other personal details: Severe disability; degree of care; marital status; employment status.
Situation: Membership of a specially protected group of persons; reasons for moving home; details of current housing situation.
Income and expenditure: Receipt of basic pension or Unemployment benefit II; taxable income, separated by source of income; expenditure, separated by type of expenditure; documents as evidence of type and amount of income and expenditure.
Metadata: Pseudo user ID, process ID, creation date, last update date, completion date, (client) ref ID, session ID, user ID, user object (also contains user ID and session ID), document UUIDs, document data, request ID.

Why is the data processed? (Purposes of processing)

Conducting the administrative procedure to decide on the entitlement to a certificate of eligibility for housing pursuant to Section 18 WFNG NRW by the competent authority pursuant to Section 3 (3) WFNG NRW (authority responsible for data protection pursuant to Section 1).

In particular, the declaration of consent to any necessary requests for information from the employer or the tax authority, which may have to be submitted at the time of application in accordance with Section 14 (5) WFNG NRW, shall be issued by the competent body in accordance with Section 3 (3) WFNG NRW (authority responsible for data protection pursuant to Section 3 (3) WFNG NRW). 3 WFNG NRW (authority responsible for data protection pursuant to section 1) in order to carry out requests for information in the course of the administrative procedure if the legal requirements are met.

What happens to the personal data?

The personal data is recorded electronically on the social platform and can be used in the administrative procedure to decide on the application. The data is transmitted electronically to the competent authority pursuant to Section 3 (3) WFNG NRW (authority responsible for data protection pursuant to Section 1).

What is the legal basis?

1. The processing on the social platform by the Ministry of Labor, Health and Social Affairs of the State of North Rhine-Westphalia (MAGS NRW) and IT.NRW is carried out by way of commissioned processing pursuant to Art. 28 GDPR for the competent body pursuant to Section 3 (3) WFNG NRW (authority responsible for data protection pursuant to Section 1).

2. The competent body pursuant to Section 3 (3) WFNG NRW (authority responsible for data protection pursuant to Section 1) collects the personal data on the legal basis for the administrative procedure for issuing a certificate of eligibility for housing, i.e. Art. 6 (1) subpara. 1 lit. e), Art. 9 (2) lit. b) GDPR in conjunction with §§ Sections 4, 13-15, 18, 25 WFNG NRW.

Is there an obligation to provide this personal data and what consequences can arise if the data is not provided?

Anyone wishing to obtain a certificate of eligibility for housing is obliged to provide all information on their income situation that is relevant to the decision, in particular in accordance with Sections 13-15 WFNG NRW, and to provide any evidence requested.

The information and evidence does not have to be provided electronically via the social platform, but can also be provided via other communication channels or in person.

The competent body pursuant to § 3 para. 3 WFNG NRW (authority responsible for data protection pursuant to section 1) may refuse to issue a certificate of eligibility for housing as long as the information required for the decision has not been provided.

How long will the personal data be stored?

1. Once the application has been sent, the personal data collected for the application is deleted from the social platform immediately, usually after just a few minutes.

2. In the case of the responsible body pursuant to Section 3 (3) WFNG NRW, the duration of the storage of personal data is based on the principle of storage limitation regulated in Art. 5 (1) (e) GDPR, which specifies the principle of data minimization in terms of time. The specific duration of storage shall be determined by the competent social welfare institutions on their own responsibility.

4.3. Cross-data processing for various electronic applications

The processing steps described in this section 4.3 are implemented uniformly for all applications that can be submitted electronically on the social platform and apply to the application procedure referred to in section 4.2 above.

4.3.1. Authentication using a new ID card or electronic residence permit

Whose personal data is processed?(Categories of data subjects)

Applicant and, if applicable, the guardian or authorized representative

Which categories of personal data are processed?

Family name
First name
Date of birth
Address

Why is the data processed? (Purposes of processing)

Media-interruption-free authentication of the applicant or the caregiver or authorized representative in order to be able to assign an application to a user of the social platform.

What happens to the personal data?

When authenticating using a new ID card (nPA) or electronic residence permit, the above-mentioned personal data is read from the secure memory chip of the nPA using the reader (e.g. chip card reader or smartphone) and transmitted directly to the local web browser via the locally installed ID card app and from there to the social platform. During this transmission, no third party acts as an intermediary for the data.

What is the legal basis?

1. The above-mentioned data is only retrieved with the consent of the applicant or the applicant's carer or authorized representative.

2. Processing on the social platform by MAGS NRW and IT.NRW is carried out by way of commissioned processing in accordance with Art. 28 GDPR for the authority responsible for the application under data protection law (in accordance with Section 1).

3. The authority responsible for the application under data protection law (in accordance with Section 1) collects the personal data on the legal basis for the respective administrative procedure. The legal basis for the administrative procedure is specified in section 4.2.

Is there an obligation to provide this personal data, and what are the consequences if the data is not provided? the caregiver or authorized representative is not legally obliged to identify themselves to the authority responsible for the administrative procedure for deciding on the application (authority responsible under data protection law in accordance with section 1) by means of an nPA or electronic residence permit.

However, all applications that can be submitted electronically via the social platform require technical legitimization, either via the nPA, electronic residence permit or a user account.

The electronic application cannot be completed without legitimization. However, the applicant or representative is still free to submit the application to the competent authority by other means.

How long will the personal data be stored?

The personal data will be deleted from the social platform with the other application data after the application has been sent to the competent authority (authority responsible for data protection in accordance with section 1).

The personal data will also be stored by the competent authority (authority responsible for data protection in accordance with section 1) in the respective administrative procedure for deciding on the application in accordance with the applicable regulations.

4.3.2. Authentication via user account

Whose personal data is processed (categories of data subjects)

Applicant and, if applicable, the data subject. caregiver or authorized representative

Which categories of personal data are processed?

Family name
First name
Date of birth
Address
Address
Mailbox of the user account
Email

Why is the data processed? (Purposes of processing)

Media-interruption-free authentication of the applicant or the caregiver or authorized representative in order to be able to assign an application to a user of the social platform.

What happens to the personal data?

When authenticating via a user account, e.g. the Servicekonto.NRW, a service account of the federal government or another federal state, the above personal data, if stored in the user account, is requested.

The data is retrieved from the authority responsible for managing the respective user account (transmission).

What is the legal basis?

1. The above-mentioned data will only be retrieved with the consent of the applicant or the caregiver or authorized representative in accordance with Section 8 (6) OZG.

3. The authority responsible for the application under data protection law (in accordance with section 1) collects the personal data on the legal basis for the respective administrative procedure. The legal basis for the administrative procedure is specified for the respective procedure in Section 4.2.

Is there an obligation to provide this personal data and what are the consequences if the data is not provided? the caregiver and authorized representative is not legally obliged to legitimize themselves to the authority responsible for the administrative procedure for deciding on the application (authority responsible for data protection in accordance with section 1) by means of a user account or to consent to the transfer of data.

However, all applications that can be submitted electronically via the social platform require technical legitimization, either via the nPA, electronic residence permit or a user account.

The electronic application cannot be completed without legitimization. However, the applicant or the caregiver and authorized representative are still free to submit the application to the competent authority by other means.

How long will the personal data be stored?

The personal data will be deleted on the social platform with the other application data after the application has been sent to the competent authority (authority responsible for data protection in accordance with section 1).

4.3.3. Inclusion of data from the user account in the application

Whose personal data is processed?(Categories of data subjects)

Applicant and, if applicable, caregiver or authorized representative

Which categories of personal data are processed?

Family name
First name
Date of birth
Address
Salutation
Email

Why is the data processed? (Purposes of processing)

Transfer of the above personal data of the applicant or the caregiver or authorized representative to pre-fill the application form.

What happens to the personal data? the caregiver or authorized representative authenticates themselves at the beginning of the application, e.g. the Servicekonto.NRW, a service account of the federal government or another federal state, the above personal data can be transferred to the respective application, provided that it is stored in the user account.

The data is retrieved from the authority responsible for maintaining the respective user account (transmission).

All transferred data can be changed and overwritten here by the applicant or the caregiver or authorized representative.

What is the legal basis?

1. The transfer of the above-mentioned data only takes place with the consent of the applicant or the caregiver or authorized representative.

2 The processing on the social platform by MAGS NRW and IT.NRW is carried out by way of commissioned processing in accordance with Art. 28 GDPR for the authority responsible for the application under data protection law (in accordance with Section 1).

3 The authority responsible for the application under data protection law (in accordance with Section 1) collects the personal data on the legal basis for the respective administrative procedure. The legal basis for the administrative procedure is specified for the respective procedure in section 4.2.

Is there an obligation to provide this personal data and what are the consequences if the data is not provided? The applicant or the caregiver or authorized representative is not legally obliged to consent to the data transfer.

If the applicant or the caregiver or authorized representative does not consent to the processing, the information must be entered themselves.

How long will the personal data be stored?

The personal data in the application will be stored on the social platform and deleted from the social platform with the other application data after the application has been sent to the competent authority (authority responsible for data protection in accordance with section 1).

The personal data will also be stored by the competent authority (authority responsible for data protection pursuant to section 1) in the respective administrative procedure for deciding on the application in accordance with the applicable regulations.

4.3.4. Storage of unsent applications

Whose personal data is processed?(Categories of data subjects)

The data of the same persons submitting the request.

Which categories of personal data are processed?

The same categories as in the respective request.

Why is the data processed?(Purposes of processing)

To enable the interruption and subsequent completion of an application, for example to provide further information or documents relevant to an application.

What happens to the personal data?

The data is stored in the social platform database. The storage of unsent applications is only possible if the applicant or the caregiver or authorized representative has authenticated themselves with a user account. Beyond this, no further processing of the data takes place.

What is the legal basis?

1. Processing on the social platform by MAGS NRW and IT.NRW takes place by way of commissioned processing in accordance with Art. 28 GDPR for the authority responsible for the application under data protection law (in accordance with section 1).

2 The authority responsible for the application under data protection law (in accordance with section 1) collects the personal data on the legal basis for the respective administrative procedure, as it must be possible for the applicant - as with applications in paper form - to complete their application at a later date. The legal basis for the administrative procedure is specified for the respective procedure in section 4.2.

Is there an obligation to provide this personal data and what are the consequences if the data is not provided?

The applicant or the caregiver or authorized representative is not legally obliged to store the data on the social platform. Saved applications can be deleted at any time. However, all data must then be entered again when submitting a new application.

How long is the personal data stored?

Saved applications are deleted no later than 24 hours after the last change to the application, unless they are sent before then. After that, applications deleted from the system can still be reconstructed from encrypted data backups for a period of 6 weeks.

4.3.5. Transmission of submitted requests

Whose personal data is processed(Categories of data subjects)

The data of the same persons who submit the request.

Which categories of personal data are processed

The same categories as in the respective request.

Why is the data processed?(Purposes of processing)

To carry out the administrative procedure for deciding on the respective application.

What happens to the personal data?

After an application has been sent by clicking on the "Submit application" button, the data is technically processed and forwarded via the so-called "Central Data Exchange Infrastructure" (ZDI) to the authority responsible for the administrative procedure for the
decision on the application (authority responsible for data protection in accordance with section 1).

What is the legal basis?

1. the transfer to the "Central Data Exchange Infrastructure" (ZDI) and processing by its operator is carried out by way of order processing in accordance with Art. 28 GDPR for the authority responsible for the application under data protection law (in accordance with section 1).

2. the authority responsible for the application under data protection law (in accordance with section 1) collects the personal data on the legal basis for the respective administrative procedure. The legal basis for the administrative procedure is specified for the respective procedure in section 4.2.

How long will the personal data be stored?

The data will be deleted from the social platform by the ZDI within a few minutes immediately after processing and transmission to the responsible authority.

4.3.6. Session cookie of the form management system

Whose personal data is processed? (Categories of data subjects)

The user of the web browser used to complete the online application form.

What categories of personal data are processed

Unique identifier to recognize the user in the form management system.

Why is the data processed? (Purposes of processing)

Unique assignment of the application form to a specific browser session and assignment of the communication between the form management system and the browser.

What happens to the personal data?

The unique identifier is stored in a cookie file on the user's end device.

What is the legal basis?

1. The processing on the social platform by MAGS NRW and IT.NRW is carried out by way of commissioned processing in accordance with Art. 28 GDPR for the authority responsible for the application under data protection law (in accordance with section 1).

2. The authority responsible for the application under data protection law (in accordance with section 1) processes the personal data on the legal basis for the administrative procedure specified in section 4.2, as this processing is technically necessary for the online application.

3. If data is retrieved from the user's terminal device or stored on the terminal device, this is done by the authority responsible for the application under data protection law (in accordance with section 1) on the legal basis of Section 25 para. 2 TTDSG, as the retrieval and storage are necessary for the function of the online application.

How long is the personal data stored?

The session cookie, which contains the unique identifier, is deleted when the web browser is closed.