Privacy Policy

OrgDesignSim is an organisational-design simulation: participants restructure a virtual company over a simulated year, and educators debrief the results in class.

Controller

The controller within the meaning of Art. 4(7) GDPR is
Urs Müller, Gotenstr. 21, 10829 Berlin, Germany — info@orgdesignsim.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 to enter a simulation session.
• Display name — optional; derived from the e-mail address if omitted.
• Session code — links you to a specific educator's session.
• Simulation data — the decisions you make and the results your run produces.
• Activity timestamps.

From educators

• E-mail address — for backoffice sign-in.
• Password — stored only as a bcrypt hash.
• Session data — names, codes, configuration, participant results.
• An audit record of backoffice actions — which account did what (creating, editing, closing, archiving or deleting a scenario), when, and the IP address it came from. This is a security record: it is how an account compromise or an accidental deletion is reconstructed. It is kept for 12 months and then deleted automatically.

Legal bases

• Running the simulation 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

• Abandoned sessions are deleted automatically by an hourly job.
• Completed sessions are anonymised automatically 90 days after completion — the personal identifiers are removed; the score is kept for educator statistics.
• Login sessions expire automatically after 24 hours.
• The backoffice audit record (educator account, action and IP address) is deleted automatically after 12 months, by the same hourly job.
• Educators can delete or archive a session at any time.

Who can see your data

• Educators see the participants of their own sessions (name and joining e-mail) and their simulation results — that is the purpose of the debrief. They can delete or archive sessions.
• 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.

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 joined with; your run can be located and deleted. After anonymisation, results 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 join a session; without it you cannot take part. The display name is 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.