Privacy policy for electronic applications in the procedure for benefits for education and participation

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 when electronic applications are created via the .

We explain for each step of data processing,

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

In section 4, we explain the individual steps of data processing, 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 electronic applications, 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 for the specific application under data protection law depends on the competent authority and therefore on your current benefit entitlement. On the overview page on education and participation, select the appropriate benefit entitlement and then enter your zip code on the application page. The responsible data protection officer will then be displayed. The data protection officer or the data protection officer of the respective authority should be contacted directly for data protection inquiries. 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 assert the following rights as a data subject against the respective responsible authority (in accordance with point 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 point 1) shall provide a copy of the personal data processed.

3.2. Right to rectification

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

3.3. Right to erasure

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

3.4. Right to restriction of processing

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

3.5. Right to data portability

Data subjects may, in accordance with Art. 20 GDPR, data subjects may receive the personal data concerning them in a structured, commonly used and machine-readable format and have the right to transmit those data from one controller to another, where the conditions set out in Art. 20 GDPR are met.

3.6. Right to object to processing

Data subjects have the right to object, on grounds relating to their particular situation, to processing of personal data concerning them which is based on Art. 6(1)(1) lit. 1 UAbs. 1 lit. e) DSGVO.

The authority will then no longer process the personal data unless it can demonstrate and, if necessary, prove that the conditions for continuing the processing of this data in accordance with Art. 21 DSGVO 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, discuss the application that can be submitted electronically for education and participation benefits via the social platform.

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 in each case as an additional processor for the authority responsible for data protection (in accordance with Section 1) pursuant to Art. 28 GDPR in conjunction with Section 80 SGB X. § Section 80 SGB X.

4.2. Electronic applications for benefits

In the following, we present the application in detail.

Application for benefits for education and participation


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

Applicants, including, for example, representatives or carers

Beneficiaries, e.g. children, young people

.e.g. children, adolescents

Other persons with a family or similar relationship to the beneficiary


What categories of personal data are processed?

  • Master data on the applicant: surname, first name, academic degree information, date of birth, nationality


    Contact data on the applicant: telephone number, email address, address

    Authorized representative master data: Surname, first names, name of company, association or other organization, relationship to the person making the application, proof of power of attorney

    Contact details of authorized representative: telephone number, e-mail address, address
  • Determination of requirements - drawing benefits: Client number/BG no., SGB XII file number, housing benefit number, Child allowance number, AsylbLG file number, explanation of other benefits, explanation of not receiving benefits
  • Master data on children: Surname, first name, date of birth, gender
  • Needs for education and participation: Requirements for (school) excursions and class trips, proof of school excursions and (class) trips, proof of special ticket approved by the school administration office, school supplies allowance, requirements for school transport, proof of school transport, requirements for learning support, proof of learning support, Statement from the school on learning support, requirements for lunch, proof of lunch, requirements for participation in social and cultural life, proof of participation in social and cultural life, personal school requirements, proof of cost disbursement
  • Details of the school or institution: Institution attended (school or children's institution), name of school / institution
  • Financial details: Bank account details
  • 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, application ID


Why is the data processed? (Purposes of processing)

Conducting the administrative procedure to decide on the entitlement to benefits for education and participation.

What happens to the personal data?

The personal data is recorded electronically on the social platform and transmitted electronically to the competent body (authority responsible for data protection in accordance with section 1). The information is then processed by the competent authority for the decision on benefits for education and participation in the administrative procedure.


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 in conjunction with Section 80 SGB X for the responsible authority. § Section 80 SGB X for the competent body (authority responsible for data protection pursuant to Section 1).

2. The competent body (authority responsible for data protection pursuant to Section 1) collects and processes the personal data on the legal basis for the administrative procedure for benefits for education and participation, i.e. Art. 6 para. 1 subpara. 1 lit. e in conjunction with. §§ 28-30 SGB II, §§ 34-34c SGB XII in conjunction with §§ 67 ff. §§ 67 ff. SGB X, § 6b BKGG, §§ 2-3 AsylbLG.


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

Whoever wishes to apply for benefits for education and participation is legally obliged to provide all information relevant to the decision and, if necessary, to provide any requested evidence. If the required data is not provided, the application cannot be processed properly.

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 (authority responsible for data protection in accordance with section 1) can refuse the application as long as the information required for the decision is not available.


How long will the personal data be stored?

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

2 At the responsible body, the duration of the storage of personal data is based on the principle of storage limitation regulated in Art. 5 para. 1 lit. e GDPR, which specifies the principle of data minimization in terms of time. The responsible bodies determine the specific duration of storage on their own responsibility.


4.3. Cross-border 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 mentioned 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 caregiver 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 carer 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 the 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 caregiver or authorized representative.

2. The processing on the social platform by MAGS NRW and IT.NRW is carried out by way of order processing in accordance with Art. 28 GDPR in conjunction with Section 80 SGB X for the respective applicant. § Section 80 SGB X 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 applicant or the applicant's authorized representative is not legally obliged to provide personal data. authorized representative is not legally obliged to identify themselves to the authority responsible for the administrative procedure for deciding on the application (authority responsible for data protection pursuant to 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, caregiver or authorized representative


Which categories of personal data are processed?

  • Family name
  • First name
  • Date of birth
  • Address
  • Salutation
  • Mailbox of the user account
  • E-Mail


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 is requested if it is stored in the user account.

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.

2. The processing on the social platform by MAGS NRW and IT.NRW is carried out by way of order processing in accordance with Art. 28 GDPR in conjunction with Section 80 SGB X for the respective applicant. § Section 80 SGB X 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 of not providing the data? 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).

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.


4.3.3. 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
  • Address
  • 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 without media discontinuity.


What happens to the personal data?

If the applicant or the caregiver or authorized representative authenticates themselves via a user account at the beginning of the application process, 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 takes place by way of commissioned processing in accordance with Art. 28 GDPR in conjunction with Section 80 SGB X for the respective social platform. § Section 80 SGB X 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 will be stored in the application 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 pursuant to 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 regulations applicable there.


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 are the data processed? (Purposes of processing)

To enable the interruption and subsequent completion of an application, for example to provide further information or documents that are 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. The processing on the social platform by MAGS NRW and IT.NRW takes place by way of commissioned processing in accordance with Art. 28 GDPR in conjunction with Section 80 SGB X for the respective social platform.

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 24 hours after the last change to the application, unless they are sent beforehand. 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 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 are the data processed? (Purposes of processing)

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


What is the legal basis?

1. The forwarding 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 in conjunction with Section 80 of the German Social Code (SGB X).

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 is 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)

User of the web browser through which the online application form is completed.


Which 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 in conjunction with Section 80 of the German Social Code (SGB X). § Section 80 SGB X for the respective authority responsible for the application under data protection law (in accordance with Section 1).

2. The respective 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. Insofar as 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.

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