Deutsche Post AG proved that its IT-based service NEXELLENT complies with EU data protection law. Customers of Deutsche Post AG may use the service to calculate statistics on the effects of physical advertising (i.e. mailings) on Internet usage (i.e. website clicks). They can be sure that processing of personal data of their own customers (consumers) is in line with the demanding provisions of EU data protection law as well as the EuroPriSe interim requirements regarding Article 5(3) of the amended ePrivacy Directive.
Function as provided in April 2014
Qualification: IT-based service
View the NEXELLENT Certificate
20/08/2014 – 31/08/2016
NEXELLENT Short PublicReport [PDF]
Deutsche Post AG
Abt. 1Q2 Online Marketing Solutions
NEXELLENT adheres to the principle of data avoidance and minimisation by aggregating user data as soon as possible and by establishing a system of informational separation of powers.
The evaluation demonstrated that NEXELLENT meets the EuroPriSe interim requirements regarding Article 5(3) of the amended ePrivacy Directive (e.g., notice & choice and first steps towards opt-in). The certification does not confirm compliance of NEXELLENT with the prior opt-in requirement of Article 5(3). EuroPriSe will consult its new advisory board as soon as it will have started its work on how to deal with Article 5(3) in future certification projects.
NEXELLENT is an analysis process that serves to determine key statistical indicators for cross-media usage. The goal is to calculate statistics on the effects of physical advertising (i.e. mailings) on Internet usage (i.e. website clicks).
A company participating in the NEXELLENT process (e.g., an online shop) has postal or billing addresses of its customers (consumers) on file. Each address is assigned to a so-called microcell from Deutsche Post Direkt GmbH, a subsidiary of Deutsche Post. A microcell is made up on average of 6.6 households. Data matching is triggered as soon as a consumer registers on the homepage of one of the companies participating in the NEXELLENT process. The result of the data matching is a randomly generated code that is stored in a database. In parallel to the data matching process with Deutsche Post Direkt GmbH, a cookie is saved on the consumer’s computer, which is linked to the randomly generated code. The cookie is valid for six months.
Internet usage is recorded at an aggregate level (microcell), which means that personal data such as name, address or any unique identifier is not used in the statistical overview. The data transfer requires the IP address, but it is transferred encoded and not used downstream in the process.
The ToE includes
- processing activity in order to locate consumers within a microcell of Deutsche Post Direkt incl. a marking of consumers on the Internet creating reference files by parties involved in the NEXELLENT – System
The ToE does not include
- data transfer by networks / the Internet or mobile networks
- the hardware of the user / client who has access to a website
- further data processing by parties involved in the NEXELLENT – System
Deutsche Post AG provides privacy relevant information on NEXELLENT as well as a possibility to opt-out from the system at http://www.deutschepost.de/de/c/nexellent.html.
DPA Drewes Privacy Advice GmbH
Dr. Stefan Drewes
DPA Drewes Privacy Advice GmbH
Formerly Certified Versions