Privacy Policy
The Layoff Exercise asks participants to rank candidates in a fictional layoff scenario, to support classroom discussion of decision-making criteria and fairness.
Controller
The controller within the meaning of Art. 4(7) GDPR is
Urs Müller, Gotenstr. 21, 10829 Berlin, Germany —
info@layoff-exercise.org.
Who is responsible for what. For educator and administrator accounts, for security and abuse prevention, and for the anonymised, aggregated analysis dataset, we are the controller. Where an institution has contracted us to run this tool for its own programme, the institution is the controller for the identifiable data of that cohort, and we process it on the institution's behalf (Art. 28 GDPR). In practice: for a request concerning your cohort's identifiable data, please approach your educator or institution first; for anything concerning accounts, security or the aggregate dataset, contact us. We assist the institution in answering requests in either case (Art. 28(3)(e) GDPR).
Data protection officer: no data protection officer is appointed. § 38 BDSG has three separate triggers and we have assessed all three: headcount (at least 20 persons constantly engaged in automated processing — this service is operated by one person), processing that requires a data protection impact assessment under Art. 35 GDPR, and commercial processing for the purpose of transfer, anonymised transfer, or market or opinion research. The last two apply regardless of headcount. Our assessment is recorded in DPIA-DETERMINATION.md and is revisited whenever the scope or purpose of processing changes — in particular if cross-class research use becomes a purpose in its own right rather than support for the individual course.
What data we process
From participants
- E-mail address — required; identifies your submission and prevents duplicates.
- Class code — groups participants by class.
- Ranking decisions — your responses to the exercise.
- Optional demographics — only the fields you choose to answer.
- Submission timestamps.
From educators
- E-mail address — for backoffice sign-in.
- Password — stored only as a bcrypt hash.
- Class data — names, codes, configuration, responses.
- An audit record of backoffice actions — the educator's e-mail address and the IP address an action came from, written to a log file. This is a security record: it is how an account compromise is reconstructed. The file rotates monthly and is kept for 12 months.
Legal bases
- Running the exercise and the class debrief — Art. 6(1)(f) GDPR, our legitimate interest in supporting the educational programme in which participants take part.
- Educator accounts — Art. 6(1)(b) GDPR.
- Security, rate-limiting and abuse prevention — Art. 6(1)(f) GDPR.
Recipients and third-country transfers
We use no third parties for advertising, analytics or tracking, and we do not sell or share personal data for marketing purposes. The following providers process data on our behalf as processors under a data processing agreement pursuant to Art. 28 GDPR:
- IONOS SE (Germany) — hosting and outgoing e-mail.
- Microsoft Ireland Operations Ltd. (OneDrive) — storage of the weekly off-site backup copies. Those backups are encrypted before they leave the server, and the private key exists only on the operator's own machine — never at the provider. So Microsoft holds ciphertext it cannot read.
- healthchecks.io — monitoring that the backup run happened. Only status pings are sent ("run succeeded / failed"); no content and no participant data.
Transfers outside the EU/EEA: processing takes place in the EU; the servers and databases are in Germany. Two things are worth stating in full. Microsoft (OneDrive) provides for transfers outside the EEA under Art. 46 GDPR safeguards (EU standard contractual clauses) — what reaches it is only the backup copies, encrypted before they leave the server, whose key we do not hand over. And healthchecks.io runs infrastructure in the EU and the US, but receives only backup-run status pings: no participant data and no content.
What this means for erasure: when a record is deleted, a copy may remain inside backups until those expire: up to 14 days in the backups held on the server, and up to 30 days in the encrypted off-site copies. Backups are used only to restore the service after a failure, never for ordinary processing.
How long we keep data
- Automatic anonymisation: classes whose responses are older than 60 days are anonymised automatically (hourly check) — e-mail addresses are deleted; rankings are kept for aggregate analysis.
- Educator-triggered anonymisation: educators are asked to anonymise a class as soon as the session is finished, and can do so at any time.
- Backoffice audit log: rotated monthly and deleted after 12 months.
Who can see your data
- Educators see the participants of their own classes (e-mail addresses) and the class's responses for the debrief.
- The administrator has technical access for maintenance and security only.
Data security
- The server is located in Germany.
- All transmission is encrypted using HTTPS/TLS.
- Passwords are stored only as bcrypt hashes, never in plain text.
- Session cookies are signed and HTTP-only.
- Web fonts are served from our own server — no third-party CDNs, so no data flows to third parties when fonts load.
- IP addresses processed for rate-limiting are held in memory only and never written to the database.
Server log files
Our web server records standard access log entries: IP address, date and time, the resource requested, HTTP status, referrer and browser identifier. These logs are used solely to operate and secure the service, are not combined with other data, are not used to identify individuals or build profiles, and are rotated and deleted after 14 days. IP addresses processed for rate-limiting are held in memory only and never written to the database.
Your rights
You have the following rights:
- Access (Art. 15 GDPR) — what data we hold about you.
- Rectification (Art. 16 GDPR) — correction of inaccurate data.
- Erasure (Art. 17 GDPR) — deletion of your personal data.
- Restriction of processing (Art. 18 GDPR).
- Data portability (Art. 20 GDPR) — your data in a structured, machine-readable format.
- Withdrawal of consent (Art. 7(3) GDPR) — at any time, with effect for the future, as easily as it was given.
Your right to object. Where we process your data on the basis of our legitimate interests (Art. 6(1)(f) GDPR), you have the right to object to that processing at any time, for reasons arising from your particular situation. If you object, we will stop processing unless we can demonstrate compelling legitimate grounds that override your interests. To object, write to info@layoff-exercise.org.
Response time. We aim to respond to enquiries promptly. Requests concerning your personal data are answered within the period required by Art. 12(3) GDPR (one month at the latest).
Erasure and withdrawal on this tool
Before anonymisation, write to us or to your educator naming the e-mail address you used; the submission can be located and deleted. After anonymisation, responses are no longer linked to a person.
Whether you must provide data
Providing data is neither a statutory nor a contractual requirement, but an e-mail address is technically required to take part (it prevents duplicate submissions); without it a submission cannot be recorded. Demographic fields are optional.
Supervisory authority
You also have the right to lodge a complaint with a data protection supervisory authority. The authority competent for our location is:
Berliner Beauftragte für Datenschutz und Informationsfreiheit
Alt-Moabit 59–61
10555 Berlin
Germany
www.datenschutz-berlin.de
Automated decision-making
No automated decision-making, including profiling, within the meaning of Art. 22 GDPR takes place.
Diese Datenschutzerklärung ist auch auf Deutsch verfügbar.