European Privacy Seal for www.vbl.de (Website Pilot)

Product/Version

www.vbl.de

Function as provided in August 2015

Qualification: Website

View the www.vbl.de certificate

Cert. No.

EP-W-PPR1FL (pilot)

Validity

26/08/2015 - 31/08/2017

Monitoring

04/2016 (O.K.)

12/2016 (O.K.)

Inspection Catalogue v0.2
(pilot phase)

Within the pilot phase regarding the new EuroPriSe certification product "website certification", only a shortened version of the applicable inspection catalogue is made publicly available. Based on the experiences of the pilot phase, an updated version of the inspection catalogue will be published at the beginning of regular operation of the new product "website certification". This updated version will be pubished in full. View the shortened version of Inspection Catalogue v0.2.

Website Owner

VBL. Versorgungsanstalt des Bundes und der Länder
Hans-Thoma-Straße 19
76133 Karlsruhe
Germany

Scope

Website certification covers the publicly available parts of a website. It focuses on the interaction between a visitor of a website and the website when the visitor browses the publicly available parts of the website. By contrast, it does not cover data protection issues related to website content (e.g., published pictures, videos and personal data in textual format).

Access restricted parts of a website are out of scope, but may be certified as an IT-based service according to the respective EuroPriSe requirements. The same holds true for other website offerings that qualify as an IT-based service (e.g., web shops).

In the case at hand, it must be stressed that the customer portal "Meine VBL" is out of scope of the EuroPriSe website certification. In addition, forms and other functionalities of the website that are not directed to all visitors of the website, but only to customers of VBL, have been examined in respect of communication security, but not in terms of data avoidance and minimization.

Target of Evaluation

The target of evaluation of the website pilot certification project www.vbl.de includes:

• All information (DE+EN) on the website that ensures transparency towards website visitors as far as data protection issues are concerned, namely
  • the imprint,
  • the privacy policy,
  • the information that is provided via the cookie banner and
  • the cookie policy;
• Processing of visitors' IP addresses;
• Use of browser cookies;
• Communication security of personal data submitted by means of forms (proper encryption); 
• Processing of personal data upon subscription to VBL's newsletter;
• Functionality that allows visitors to recommend some forms in the download section of the website.

The ToE does not include:

• Hosting of the webserver by a third party (contract + TOMs);
• Customer portal "Meine VBL";
• Data protection issues that go beyond communication security with regard to forms that are not directed to all visitors of the website, but only to customers of VBL (e.g., contact form for customers).

Evaluation Result

The legal and technical evaluation by the EuroPriSe Experts confirmed that visitors of the publicly available parts of the website www.vbl.de can be sure that VBL complies with all relevant requirements of the General Data Protection Directive (95/46/EC) and of the Directive on Privacy and Electronic Communications (2002/58/EC) as far as interaction between website visitors' browsers and the webserver is concerned.  

Technical Evaluator

Andreas Sütterlin
SüdWest Datenschutz Rechtsanwaltsgesellschaft mbH
Rüppurrer Straße 4
76137 Karlsruhe
Germany

Legal Evaluator

Nicole Schmidt
SüdWest Datenschutz Rechtsanwaltsgesellschaft mbH
Rüppurrer Straße 4
76137 Karlsruhe
Germany