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2020 Corporate Responsibility Report

Our approach to data protection

Our contribution to the SDGs

The highest standards of data privacy and data security are part of our brand identity. Our active data protection and compliance culture, which has been built up over ten years, sets national and international standards.

The Board department for Data Privacy, Legal Affairs and Compliance (DRC), established in 2008, was dissolved effective at the end of the term of office of Dr. Thomas Kremer, Board member for DRC, on March 31, 2020. As of January 1, 2020, the individual areas of this department were assigned to other Board departments (“Finance,” “Human Resources,” “Technology and Innovation”). Chief Human Resources Officer Birgit Bohle has headed up the extended Human Resources and Legal Affairs Board department since January 1, 2020.

Since 2009, the Group Board of Management has been advised by an independent Data Privacy Advisory Board comprising reputable experts from politics, science, business, and independent organizations. At the beginning of 2020, the Advisory Board took on a bigger role through the addition of new members from the Board of Management and the Supervisory Board of Deutsche Telekom AG.
Deutsche Telekom Security GmbH combines the security activities from various Group areas, thereby reinforcing our portfolio of cybersecurity solutions.

Underlying regulations
Data protection and data security at Deutsche Telekom are subject to the following regulations:

  • The Binding Corporate Rules on Privacy govern the handling of personal data.
  • The Group Security Policy includes significant security-related principles followed within the Group.

Both guidelines set forth binding standards that are in line with international standard ISO 27001. These policies allow us to guarantee an adequately high and consistent level of security and data privacy throughout the Group.

Ensuring effective data privacy

  • Consistent transparency vis-à-vis the public
    We provide comprehensive information about our data protection activities such as the implementation of the GDPR at We have also published an annual transparency report since 2014. Moreover, in the Consumer protection section of this CR report we explain how we make our products and services safe for users.
  • Regular employee training courses
    Telecommunications companies are obliged to provide new employees with information on data privacy regulations. We go above and beyond these legal requirements. Every two years, we train all Group employees and place them under an obligation to uphold data privacy and telecommunications secrecy.
    We have also introduced specific training in the customer and human resources departments. This training includes online courses for independent learning, presentations on data privacy and face-to-face courses on specific topics such as data protection at call centers. This helps us ensure that all employees have in-depth understanding of the relevant data privacy policies.
  •  Regular review and adaptation of measures
    Every two years, we conduct an annual Group data privacy audit to measure and improve the general data privacy standards throughout the Group 15 percent of the Group employees, who are randomly selected, are asked to participate in an online survey. The Group data privacy audit is supplemented by internal and external on-site checks.
    Group Privacy assesses the results and checks whether action needs to be taken in the respective units. Where necessary, the Global Data Privacy Officer calls for improvement measures and, to this end, holds personal meetings with the responsible directors, managers, and data privacy officers at the different departments. Group Privacy offers advice on the implementation of the measures and determines whether they are effective. We take unusual audit results into consideration when planning the follow-up audit.
  • Certifications
    We have our processes, management systems, products, and services certified by external, independent organizations such as TÜV, DEKRA, and auditing firms. This reporting year, TÜV Nord once again confirmed that the IT systems used by Telekom Deutschland are safe and secure.

Our approach to big data and artificial intelligence
When very large volumes of data are being processed, we must take precautionary measures to protect citizens’ privacy, which is why, back in 2013, we approved eight mandatory principles for handling big data. In 2015, we also approved specific measures to protect data and infrastructure in our “Ten-point program for increased cybersecurity.” Against this background, we have developed special protective products, including our Mobile Encryption app, which ensures end-to-end encryption of mobile communication for smartphone users. Furthermore, in 2018 we published a Guideline for designing artificial intelligence (AI) in compliance with data privacy requirements.

Reviewing our products
Data privacy and security play an important role that starts during the development of our products and services. Our Privacy and Security Assessment (PSA) procedure allows us to review the security of our systems in each step of the development process. This procedure applies to newly developed systems as well as existing systems that undergo changes in technology or in the way data is processed. We use a standardized procedure to document the data privacy and data security status of our products throughout their entire life cycle.

Reporting against standards


Sustainability Accounting Standards Board (SASB)

  • Code TC-TL-220a.1 (Data Privacy)
  • Code TC-TL-230a.2 (Data Security)