This privacy notice explains how your data is processed and what data protection rights you have when using the German Federal Government’s official coronavirus app, the Corona-Warn-App.
It covers the following topics:
To make sure that this text can be understood by all users, we have made every effort to make it simple and as non-technical as possible.
This app is published by the Robert Koch Institute (RKI) for the German Federal Government. The RKI is also responsible for ensuring that your personal data is processed in accordance with data protection regulations.
If you have tested positive for coronavirus, you can use the transnational warning feature to also warn users of the official coronavirus apps of other countries whom you have encountered. In this case, the RKI and the competent health authorities of the countries participating in the transnational warning system are so-called joint controllers, meaning they are jointly responsible for data processing. Please refer to Section 7 for more details.
Using the app is voluntary. It is entirely up to you whether you install the app, which of the app’s features you use, and whether you share data with others. All of the app’s features that require the transfer of your exposure or health data will obtain your express consent in advance. If you do not give your consent or if you subsequently withdraw it, this will not result in any disadvantages for you.
The RKI will only process your data if you have given your express consent beforehand. The legal basis is Art. 6(1) Sentence 1(a) GDPR and, in the case of health data, Art. 9(2)(a) GDPR. After giving your consent, you can withdraw it at any time (so-called right of withdrawal). Please refer to Section 12 for further information about your right of withdrawal. On the basis of Art. 6(1) Sentence 1(e) GDPR in conjunction with Sect. 3 of the German Federal Data Protection Act (BDSG), the processing of access data for the retrieval of daily statistics (see Section 6 d.) is performed as part of the RKI’s duty to inform the public pursuant to Sect. 4(4) of the Act on Successor Agencies to the Federal Health Agency (BGA-NachfG).
The app is aimed at people who are resident in Germany and at least 16 years old.
The app’s entire system has been programmed to process as little personal data as possible. This means that, when you use exposure logging, warn other users, or retrieve a test result, the system does not collect any data that would allow the RKI or other users to infer your identity, your name, your location or other personal details.
In principle, the app does not therefore use any analysis tools to evaluate the way you use it. Only if you expressly agree to voluntarily share data (see Section 5 e.), will certain data about your use of the app be transmitted to the RKI.
The data processed by the app can be grouped into the following categories:
Every time the app exchanges data over the internet with the RKI’s server system (hereinafter referred to as the server system), the server system processes so-called access data. This is necessary so that the app can retrieve current data (e.g. for warnings) or transmit certain data stored on your smartphone to the server system. This access data includes the following:
This access data is processed to maintain and secure the technical operation of the app and the server system. You will not be identified personally as a user of the app and no user profile will be created. Your IP address will not be stored beyond the end of the usage procedure.
In order to prevent unauthorised parties from using your IP address to associate your data with you when you use the app, the app only ever accesses the server system via a special access server. This access server then forwards the data requested or transmitted by the app to the appropriate server, but without your IP address, meaning that your IP address is no longer processed within the server system.
As soon as you enable your iPhone’s or your Android smartphone’s COVID-19 exposure notification system (which is called “Exposure Notifications” or “COVID-19 Exposure Notifications” respectively), your smartphone transmits so-called exposure data via Bluetooth, which other smartphones in your vicinity can record. Your smartphone, in turn, also receives the exposure data of other smartphones. The exposure data transmitted by your smartphone comprises:
If exposure to another smartphone is recorded, the exposure data also includes:
The random IDs are changed regularly. This helps prevent your smartphone from being identified using these random IDs. The exposure data transmitted by your smartphone and the exposure data recorded when you come into contact with other app users are stored on your smartphone and deleted after 14 days. The exposure data transmitted by your smartphone is processed in the same way when it is recorded by the smartphones of other app users.
Please note: the COVID-19 exposure notification system functionality is part of your operating system. The providers responsible for this system are therefore Apple (if you have an iPhone) and Google (if you have an Android smartphone). In this respect, the data processing is subject to these companies’ own privacy policies, which means that the RKI is not responsible for this and has no influence on it. Depending on the version and configuration of your operating system, the actual names, operating steps and settings options may differ from those described in this privacy notice. More information is available from the respective providers:
Health data is any data containing information about a person’s health. This includes not only information about past and current illnesses, but also about a person’s risk of illness (such as the risk that a person has been infected with coronavirus). The app processes health data in the following cases:
Section 6 explains this in more detail.
If you use the contact journal to note when and where you met certain people, this information is stored in encrypted form on your smartphone. The contact journal entries are only there to help you remember. The RKI and other agencies cannot gain access to entries in the contact journal. The contact journal can help you to keep track of your personal contacts over the last 14 days. If you test positive for coronavirus and the public health office (Gesundheitsamt) requests your assistance with contact tracing, then you can quickly provide the information it needs.
Using the contact journal is voluntary. You personally decide whether to store entries in the contact journal. In this respect, you are also responsible for what you record. For this reason, we kindly ask you to respect the privacy of the people you include in your contact journal. You should not share your entries with third parties or via insecure communication channels. The competent public health office will tell you what information it needs from you for contact tracing purposes, and how you can provide it.
If you enable the data sharing feature, the app will transmit various data about your use of the app (hereinafter referred to as usage data) once a day to the RKI. This usage data concerns possible exposures and warnings that have been displayed to you, test results you have retrieved, and whether you have warned other users, and information about your smartphone’s operating system. Specifically, this means:
If you retrieved a test result via the app:
If you have warned others about a possible exposure:
Other information:
In addition, you can provide further voluntary information about your region and age group, which will be transmitted to the RKI together with the usage data.
The RKI will compile the usage data and other voluntary information into statistics and analyse it to assess the effectiveness and functioning of the app, and draw conclusions regarding the pandemic.
Using the data sharing feature is voluntary. You decide yourself whether you want to enable the data sharing feature and whether usage data and other voluntary information should be transmitted to the RKI. To enable the data sharing feature, the authenticity of your app first needs to be confirmed (please note the further information about this in Sections 5 g. and 11).
Some app users are offered to participate in a survey by the RKI. This offer to participate in the survey will usually be contingent on certain events registered in the app (e.g. an elevated risk being displayed). By taking part in the survey, you will help the RKI to assess the effectiveness of the app, to improve the app and, for example, to understand whether and how warnings sent via the app help to prevent further infections.
Participation in the surveys is voluntary. You decide yourself whether you want to participate in a survey and whether data should be transmitted to the RKI for this purpose. The surveys take place on a website outside of the app, which you will be redirected to. To enable participation in a survey, the authenticity of your app first needs to be confirmed (please note the further information about this in Sections 5 g. and 11).
Before you can use some of the app’s features, the authenticity of your app first needs to be checked and confirmed to the RKI. This process uses a feature of your smartphone’s operating system. Your smartphone generates a unique identifier and sends it to your operating system provider (if you use an Android smartphone, data is transmitted to Google; if you use an iPhone, data is transmitted to Apple). The identifier contains information about the version of your smartphone and the version of the app. It is possible for your operating system provider to infer your identity from the identifier and learn that your smartphone has been authenticated. Your operating system provider does not receive any other information, such as exposure data, from the app. Your operating system provider will use the identifier to confirm the authenticity of your app to the RKI. Using the feature for confirming the authenticity of your app is voluntary. However, if you do not agree to having the authenticity of your app confirmed, other features of the app may not be available to you.
Exposure logging is part of the app’s main functionality. It serves to warn you of possible exposure to people who have tested positive for coronavirus (“possible exposures”) in a number of different countries, to assess the risk that you have been infected as a result of the exposure, and to provide you with health advice and recommendations for what to do next.
For this purpose, the app retrieves an up-to-date list from the server system several times a day. This list contains the random IDs, along with any voluntary symptom information, of users who have tested positive for coronavirus and used the warning feature in their app, which is the official coronavirus app in any country participating in the transnational warning system (see Section 7) (hereinafter referred to as a positive list). The random IDs on the positive list also contain a transmission risk value and an indication of the type of diagnosis (see Section 6 c.).
The app passes the random IDs from the positive list to the COVID-19 exposure notification system, which compares them with the random IDs it has recorded from your encounters with other users. If the COVID-19 exposure notification system detects a match, it transfers to the app the exposure data recorded for the possible exposure in question. The app evaluates this exposure data as well as the information on the positive list (transmission risk value; information about the onset of symptoms) in order to determine your risk of infection. The rules for evaluating this information (for example, how the duration of a contact influences the risk of infection) are based on the RKI’s latest scientific findings. In the event of new findings, the RKI can update the evaluation rules by adjusting the evaluation settings in the app. In this case, the new evaluation settings are sent to the app together with the positive list.
The risk of infection is calculated exclusively offline in the app and is not passed on to the COVID-19 exposure notification system or any other recipient (including the RKI, other health authorities in Germany or other countries, Apple, Google and other third parties).
If a risk of infection is identified for you, this will be displayed in the app. If an elevated risk is displayed, this means that you encountered one or more other users who later tested positive for coronavirus and used the warning feature in their app. The risk calculated for each of the last 14 days is displayed in the calendar view of the contact journal. Please refrain from drawing false conclusions about the source of any risk: a risk calculated and displayed for a certain day may well be due to your having encountered users unknown to you without realising it, and will not necessarily have anything to do with the people or places you recorded in the contact journal.
If you have taken a coronavirus test, you can retrieve your test result via the app. The app will notify you as soon as your test result is available. For this to work, the testing laboratory needs to be connected to the server system and, as part of the testing procedure, you must have given separate consent to your test result being sent. It is not possible to display test results from laboratories that are not connected to the server system. If you have not received a QR code, then you cannot use this feature either.
Scanning the QR code
In order to retrieve your test result via the app, you will need to scan the QR code using your smartphone’s camera. The QR code contains a code number that is read during scanning and is assigned to your test. After reading the code number, the app ‘hashes’ it. This means that the app performs a certain mathematical procedure in order to convert the code number in such a way that it can no longer be identified. However, it is still possible to clearly assign the hashed code number to your test result. As soon as your smartphone is connected to the internet, the app will transmit the hashed code number to the server system. The server system then provides a digital access key (a so-called token), which is stored in the app. The token is linked to the hashed code number in the server system. The app now deletes the code number that has been hashed on your smartphone and keeps only the token. Once the QR code has been used in this way, it becomes invalid and can no longer be used by anyone. This ensures that no other users can use your QR code to retrieve your test result.
Filing of the test result
As soon as your test result is available, the laboratory stores it in the RKI’s test result database using only the hashed code number. The test result database is located on a special server within the server system. The laboratory generates the hashed code number based on the same QR code that you received.
Retrieval of the test result
Using the token stored in the app, the app regularly requests the status of your test from the server system. The server system then informs the app of the current status (result not yet available / result available). As soon as your test result is available, the outcome (i.e. whether you have tested positive or negative for coronavirus) is also transmitted to the app. If you have enabled the test status notification (under “Settings” > “Notifications”), you will be notified. The test result will not be displayed until you open the app.
If you have tested positive for coronavirus, the app uses the token again to request a TAN (transaction number) from the server system. The TAN is required to ensure that no false warnings are transmitted to other users. For this purpose, the server system reassigns the token to the hashed code number and requests confirmation from the test result database that a positive test result really does exist for the hashed code number. If this is confirmed, the server system generates the TAN and transmits it to the app. A copy of the TAN remains on the server system.
If you have tested positive for coronavirus and share your random IDs with the app, then it is possible to warn other app users whom you have encountered. This applies to other users of the Corona-Warn-App as well as users of any other official coronavirus app in participating countries. In this case, the app transmits the following data to the server system:
Before passing on your test result (more precisely: before transmitting your random IDs) to the server system, the app adds a transmission risk value to the data and also specifies the type of test performed. Since the app’s warning feature can only be used for lab-confirmed test results, the type of test is the same for all users. The transmission risk value is an estimate of how infectious you were on each day of the 14-day period. Since how infectious a person is or was depends on the duration and course of the infection, it can be taken into account, for example, that the more time has passed since the onset of symptoms, the lower the risk of a person spreading the virus on the day of a possible exposure. These additional transmission risk values allow a more precise determination of the likelihood that you have infected other users.
The information requested by the app about the onset of symptoms is optional. However, this information may help to calculate the transmission risk value even more accurately. If you do not provide information about your symptoms, then the transmission risk values will be calculated assuming a typical case of infection with coronavirus, i.e. the more time has passed since a random ID was used, the lower the associated transmission risk value.
If you have not retrieved your test result in the app:
Even if you have not retrieved your positive test result via the app, you can still warn fellow users. To do this, select the “Request TAN” procedure. The app will then prompt you to call the app hotline. A hotline worker will then ask you a few questions to make sure that you really have tested positive for coronavirus. This is to prevent false warnings being transmitted, either by accident or intentionally. Once you have answered these questions sufficiently, you will be asked for your mobile/telephone number and your name. This is so that you can be called back later and given what’s called a TeleTAN to enter in the app. Your mobile/telephone number and your name will be temporarily stored for this purpose only and deleted after an hour at the latest. Immediately after your call, the hotline worker will generate a unique TeleTAN via a special access to the server system and then call you back to tell you this TeleTAN. A TeleTAN is only valid for one hour and will therefore be deleted no later than one hour after it has been passed on to you. After a valid TeleTAN is entered in the app, it is transmitted to the server system. The TeleTAN thus makes it possible to check that a positive test result really does exist and thus prevent false alarms. The app then receives a token from the server system, as it does after a valid QR code is scanned (see “Retrieving a test result” in Section 6 b. above).
Please note that in rare cases, if you use the warning feature, people you know personally who also use the app and then receive a warning, may infer that the warning came from you. This may be the case if a person whom you know had no contact with anyone except with you on the day for which the possible exposure is displayed.
The app automatically receives the daily statistics that appear in the app via the server system. This generates access data. Websites linked in the app, such as www.bundesregierung.de, are opened and displayed in your smartphone’s standard browser (Android smartphones) or within the app (iPhones). Which data is processed in this context depends on the respective providers of the websites accessed.
The contact journal is an additional feature of the app. What you enter in the contact journal serves as a reminder for you, and can only be accessed by you. If you later test positive for coronavirus and the public health office (Gesundheitsamt) requires your assistance with contact tracing, then you can provide the information that it needs more quickly. If the app calculates an elevated risk for you for a particular day, then seeing this information may help you to warn the people you have had contact with early on. This will give your contacts the chance to decide whether to change their plans if necessary, i.e. to meet up with fewer people and thus reduce the risk of causing undetected infections.
Data sharing is an additional feature of the app. The usage data and other voluntary information transmitted to the RKI by the data sharing feature are used to assess the effectiveness of the app and enable the following improvements:
The usage data and other voluntary information will be stored and analysed without any connection to your name or identity. This means the RKI will not find out who you are or who you have met.
The surveys take place on a website outside of the app, which you will be redirected to. The app will not transmit any data to the RKI in connection with the surveys. The purposes of an RKI survey are described in the information about the survey on the survey website.
A feature of your smartphone’s operating system is used to confirm the authenticity of your app. This ensures that only app users whose app is functioning properly can share their data or participate in surveys. This prevents the statistics and survey results from being distorted.
Please note that your operating system provider may be able to tell that your smartphone has been authenticated and may therefore be able to infer your identity. However, your operating system provider will not receive any further information about your use of the Corona-Warn-App.
To ensure that users are also warned by the official coronavirus apps of other countries, the RKI, together with several official healthcare bodies and authorities in other countries (hereinafter referred to as health authorities) has set up a central warning server for sharing warnings between countries (hereinafter referred to as the exchange server). The exchange server uses the digital infrastructure of the eHealth Network established between the Member States.
The national server systems of the coronavirus apps connected to the exchange server regularly transmit their own positive lists to the exchange server and receive the positive lists of the other countries.
The server system merges the positive lists received in this way with its own positive list, which allows the exposure logging feature to also take into account possible exposures involving users of another coronavirus app (see point 6 c.) The other participating countries proceed in the same way with the positive lists provided by the RKI.
Only countries whose coronavirus apps are compatible with each other and which guarantee a comparably high level of data protection can participate in the joint exchange server. In particular, this requires that the coronavirus apps of the participating countries also use the COVID-19 exposure notification system, are approved by the respective national health authorities, and respect the privacy of their users. The technical and organisational details of this cooperation are laid down in an EU Commission Decision (Commission Implementing Decision (EU) 2020/1023 of 15 July 2020, which is available at https://eur-lex.europa.eu/eli/dec_impl/2020/1023/oj).
Together with the respective competent health authorities of the participating countries, the RKI is a joint controller under data protection law, meaning it is responsible for processing the information contained on the positive lists (random IDs and, if applicable, information about the onset of symptoms) on the exchange server in order to enable the transnational exposure logging and warning system.
Please note that the list of participating countries is subject to change. The current list, with details of the competent health authorities in each case, can be found in the FAQs available at https://www.coronawarn.app/en/faq/#interoperability_countries .
The app requires access to a number of your smartphone’s features and interfaces. For this purpose, you need to grant the app certain permissions. The permission system depends on your operating system’s specifications. For example, your smartphone may combine individual permissions into permission categories, where you can only agree to the permission category as a whole. Please note that without the permissions requested by the app, you will not be able to use some or all of the app features.
If you are using an Android smartphone, the following system features must also be enabled:
The app also requires the following permissions:
If you are using an iPhone, the following system features must be enabled:
The app also requires the following permissions:
The storage period depends on the purposes or app features for which your data has been stored. When determining the storage period, the RKI takes into account the latest scientific findings on the incubation period (i.e. the period between exposure to infection and the appearance of the first symptoms, which is up to 14 days) as well as on how long there is a risk of an infected person infecting someone else after the end of the incubation period. Unless otherwise specified under Section 6, the following storage periods apply:
The positive lists are deleted from the app memory after 14 days. The infection risk determined for you (e.g. “low risk”) is deleted from the app memory after each update, but after 14 days at the latest. If you have retrieved a positive test result, the token in the app memory is deleted as soon as you activate the warning feature. Your entries in the contact journal will be stored on your smartphone for 16 days before being automatically deleted. You can also delete these entries yourself at any time.
Positive lists are deleted from all server systems (including the exchange server) after 14 days. All other data, with the exception of data transmitted by the data sharing feature and to confirm the authenticity of your app, will be deleted after 21 days at the latest.
Usage data and other voluntary information transmitted to the RKI by the data sharing feature will be deleted after 180 days.
The identifier generated by your smartphone to confirm the authenticity of your app will be deleted from the server system after 30 days after transmission to the RKI.
If you warn other users via the app, your test result (in the form of your random IDs from the last 14 days) as well as optional information you provide about the onset of your symptoms will be forwarded to the competent health authorities of each of the countries participating in the exchange server. From there, they will be passed on to the server systems of the coronavirus apps of those countries participating in the transnational warning system. The server systems of the national coronavirus apps then distribute this information to their own users as part of the positive lists.
The competent national health authorities in the participating countries have commissioned the EU Commission, as data processor, to operate and maintain the joint warning system.
The RKI has commissioned T-Systems International GmbH and SAP Deutschland SE & Co. KG to operate and maintain part of the technical infrastructure of the app (e.g. server system, hotline), meaning that these two companies are processors under data protection law and acting on the RKI’s behalf. The EU Commission has also commissioned these companies, as sub-processors, with the technical provision and management of the participating countries’ joint warning system.
Otherwise, the RKI will only pass on your data collected in connection with your use of the app to third parties if the RKI is legally obliged to do so or if this is necessary for legal action or criminal prosecution in the case of attacks on the app’s technical infrastructure. In other cases, personal data will not generally be passed on by the RKI.
If you activate the warning feature, please note that users can retrieve the latest positive lists regardless of where they are (even if they are abroad on holiday or on a business trip, for example).
In addition, the confirmation of the authenticity of your app may involve the transfer of data to a country outside the EU. The identifier generated by your smartphone, which contains information about the version of your smartphone and the app, will be transmitted to the provider of your smartphone’s operating system (Apple or Google). This may result in data being transferred to third countries, in particular the US. There, the level of data protection may not be considered equivalent under European law and it may not be possible to enforce your European data protection rights. In particular, there is a possibility that once the transmitted data reaches the operating system provider, it may be accessed and analysed by security authorities in the third country, for example by linking the data with other information. However, this only concerns the submitted identifier. It does not concern other information from the app, such as exposure data.
Otherwise, the data transmitted by the app is processed exclusively on servers in Germany or in another country in the EU (or the European Economic Area), which are therefore subject to the strict requirements of the General Data Protection Regulation (GDPR).
You have the right to withdraw any consent you granted the RKI in the app at any time with effect for the future. Please note, however, that any processing of your data that has already been carried out cannot be reversed. In particular, once your random IDs have been transmitted, the RKI has no way of deleting these from other users’ smartphones.
You can withdraw your consent to the app’s exposure logging feature at any time by disabling the feature in the app’s settings or by deleting the app. If you would like to use the exposure logging feature again, you can re-enable the feature or reinstall the app.
You can withdraw your consent to the test result retrieval feature by displaying the test in the app and then deleting it. The token for retrieving the test result will consequently be deleted from the app memory, so that the token can no longer be assigned on the server system. It is not possible to assign the same test to your app again or to scan the same QR code again. If you have been tested again and wish to retrieve the test result, you will be asked for your consent again. If the test result is already available in the app, then you can no longer withdraw your consent.
If you would like to withdraw your consent to the transmission of your test result (or, more precisely, your consent to the transmission of your random IDs from recent days) for warning other people, you can display the test and then deactivate “Warn others”. This option is available as long as you have not yet transmitted your random IDs to warn other users.
After you have transmitted your random IDs, you can only withdraw your consent by deleting the app. Your random IDs already transmitted to the server system will consequently be deleted from the app memory and can no longer be assigned to you personally or your smartphone. If you wish to activate the warning feature again, you will need to reinstall the app and give your consent again. Once a test result has been assigned to your app and transmitted in order to warn others, it cannot be used again to warn others.
Once your random IDs and transmission risk values have been transmitted, the RKI has no way of deleting them from the positive lists distributed by the server system or from users’ smartphones. If you also wish to delete your exposure data stored in your smartphone’s COVID-19 exposure notification system, you may be able to manually delete it in your smartphone’s system settings. Please also note the information in Section 5 b.
You can withdraw your consent to the data sharing feature at any time by disabling the data sharing feature in the app’s settings. The app will then no longer transmit your usage data and other voluntary information to the RKI on a daily basis. If you would like to allow data sharing again, you can re-enable the feature in the settings.
You do not give your consent to participate in an RKI survey in the app, but via the website on which the survey is conducted. There you will also find information about how you can withdraw your consent.
If you withdraw your consent to the confirmation of your app’s authenticity, this will not directly affect the related data processing. The transmission of the identifier generated by your smartphone to the operating system provider, and the verification and confirmation of the authenticity of your app, take place immediately after you have given your consent.
If the RKI processes your personal data, you also have the following data protection rights:
You also have these data protection rights vis-à-vis the health authorities responsible for data processing in the countries participating in the exchange server, insofar as you have transmitted your random IDs from recent days to warn other people (see Section 7).
Please note that the rights mentioned above can only be fulfilled if the data on which your claim is based can be clearly assigned to you. This would only be possible if the app were used to collect further personal data that would allow the data transmitted to the server system to be clearly assigned to you or your smartphone. Since this is not necessary for the purposes of the app, the RKI is not obliged to collect such additional data (Art. 11(2) GDPR). Moreover, this would run counter to the stated objective of collecting as little data as possible. For this reason, it will generally not be possible to fulfil the above data protection rights even if you provide additional information about your identity.
If you have any questions or concerns regarding data protection, you are welcome to send them to the RKI’s official data protection officer by post to Robert Koch-Institut, FAO the data protection officer, Nordufer 20, 13353 Berlin, or by emailing datenschutz@rki.de.
Last amended: 01 March 2021