CIPPE 2 – AllNet Law

This multiple choice assessment focuses on the new General Data Protection Regulation (GDPR).

The purpose of the assessment is to enable you to assess the extent and depth of your knowledge of the Data Protection Law in preparation for the CIPP-E.

Format: Multiple Choice

Time: 90 minutes

The result will be provided immediately, with details on all questions.

Full Name

Email

1) If a company is planning to use closed-circuit television (CCTV') on its premises and is concerned with GDPR compliance, it should first do all of the following EXCEPT?

Notify the appropriate data protection authority.

Perform a data protection impact assessment (DPIA).

Create an information retention policy for those who operate the system.

Ensure that safeguards are in place to prevent unauthorized access to the footage.

2) What is the consequence if a processor makes an independent decision regarding the purposes and means of processing it carries out on behalf of a controller?

The controller will be liable to pay an administrative fine.

The processor will be liable to pay compensation to affected data subjects.

The processor will be considered to be a controller in respect of the processing concerned.

The controller will be required to demonstrate that the unauthorized processing negatively affected one or more of the parties involved.

3) Under the GDPR, which of the following is true in regard to adequacy decisions involving cross-border transfers?

The European Commission can adopt an adequacy decision for individual companies.

The European Commission can adopt, repeal or amend an existing adequacy decision.

EU member states are vested with the power to accept or reject a European Commission adequacy decision.

To be considered as adequate, third countries must implement the EU General Data Protection Regulation into their national legislation.

4) Under the GDPR, where personal data is not obtained directly from the data subject, a controller is exempt from directly providing information about processing to the data subject if?

The data subject already has information regarding how his data will be used.

The provision of such information to the data subject would be too problematic.

Third-party data would be disclosed by providing such information to the data subject.

The processing of the data subject's data is protected by appropriate technical measures.

5) Which area of privacy is a lead supervisory authority's (SA) MAIN concern?

Data subject rights

Data access disputes

Cross-border processing

Special categories of data

Please use the following to answer the next question:

Triangulate Inc. is a multinational company, headquartered in New Jersey with offices throughout the United States, Asia. and Europe (including France, Spain, Sweden and Portugal)_ Last year the company was the victim of a phishing attack that resulted in a significant data breach. The executive board, in coordination with the general manager, their Privacy Office and the Information Security team, resolved to adopt additional security measures. These included training awareness programs, a cybersecurity audit, and use of a new software tool called FirstSecurity, which scans employees' computers to see if they have software that is no longer being supported by a vendor and therefore not getting security updates.

However, this software also provides other features, including the monitoring of employees' computers. Since these measures would potentially impact employees. Triangulate's Privacy Office decided to issue a general notice to all employees indicating that the company will implement a series of initiatives to enhance information security and prevent future data breaches.

After the implementation of these measures, server performance decreased. The general manager instructed the Security team on how to use FirstSecurity to monitor employees' computers activity and their location. During these activities, the Information Security team discovered that one employee from Spain was daily connecting to a video library of movies, and another one from France worked remotely without authorization. The Security team reported these incidents to the Privacy Office and the general manager. In their report, the team concluded that the employee from Spain was the reason why the server performance decreased.

Due to the seriousness of these infringements, the company decided to apply disciplinary measures to both employees, since the security and privacy policy of the company prohibited employees from installing software on the company's computers, and from working remotely without authorization.

6) What would be the MOST APPROPRIATE way for Triangulate to handle the situation with the employee from Spain?

Since the GDPR does not apply to this situation, the company would be entitled to apply any disciplinary measure authorized under Spanish labor law.

Since the employee was the cause of a serious risk for the server performance and their data, the company would be entitled to apply disciplinary measures to this employee, including fair dismissal.

Since the employee was not informed that the security measures would be used for other purposes such as monitoring, the company could face difficulties in applying any disciplinary measures to this employee.

Since this was a serious infringement, but the employee was not appropriately informed about the consequences the new security measures, the company would be entitled to apply some disciplinary measures, but not dismissal.

Please use the following to answer the next question:

Triangulate Inc. is a multinational company, headquartered in New Jersey with offices throughout the United States, Asia. and Europe (including France, Spain, Sweden and Portugal)_ Last year the company was the victim of a phishing attack that resulted in a significant data breach. The executive board, in coordination with the general manager, their Privacy Office and the Information Security team, resolved to adopt additional security measures. These included training awareness programs, a cybersecurity audit, and use of a new software tool called FirstSecurity, which scans employees' computers to see if they have software that is no longer being supported by a vendor and therefore not getting security updates.

However, this software also provides other features, including the monitoring of employees' computers. Since these measures would potentially impact employees. Triangulate's Privacy Office decided to issue a general notice to all employees indicating that the company will implement a series of initiatives to enhance information security and prevent future data breaches.

After the implementation of these measures, server performance decreased. The general manager instructed the Security team on how to use FirstSecurity to monitor employees' computers activity and their location. During these activities, the Information Security team discovered that one employee from Spain was daily connecting to a video library of movies, and another one from France worked remotely without authorization. The Security team reported these incidents to the Privacy Office and the general manager. In their report, the team concluded that the employee from Spain was the reason why the server performance decreased.

Due to the seriousness of these infringements, the company decided to apply disciplinary measures to both employees, since the security and privacy policy of the company prohibited employees from installing software on the company's computers, and from working remotely without authorization.

7) Which institution has the power to adopt findings that confirm the adequacy of the data protection level in a non-EU country?

The European Parliament

The European Commission

The Article 29 Working Party

The European Council

Please use the following to answer the next question:

Triangulate Inc. is a multinational company, headquartered in New Jersey with offices throughout the United States, Asia. and Europe (including France, Spain, Sweden and Portugal)_ Last year the company was the victim of a phishing attack that resulted in a significant data breach. The executive board, in coordination with the general manager, their Privacy Office and the Information Security team, resolved to adopt additional security measures. These included training awareness programs, a cybersecurity audit, and use of a new software tool called FirstSecurity, which scans employees' computers to see if they have software that is no longer being supported by a vendor and therefore not getting security updates.

However, this software also provides other features, including the monitoring of employees' computers. Since these measures would potentially impact employees. Triangulate's Privacy Office decided to issue a general notice to all employees indicating that the company will implement a series of initiatives to enhance information security and prevent future data breaches.

After the implementation of these measures, server performance decreased. The general manager instructed the Security team on how to use FirstSecurity to monitor employees' computers activity and their location. During these activities, the Information Security team discovered that one employee from Spain was daily connecting to a video library of movies, and another one from France worked remotely without authorization. The Security team reported these incidents to the Privacy Office and the general manager. In their report, the team concluded that the employee from Spain was the reason why the server performance decreased.

Due to the seriousness of these infringements, the company decided to apply disciplinary measures to both employees, since the security and privacy policy of the company prohibited employees from installing software on the company's computers, and from working remotely without authorization.

8) To comply with the GDPR, what should Triangulate have done as a first step before implementing the SecurityFirst measure?

Assessed potential privacy risks by conducting a data protection impact assessment.

Consulted with the relevant data protection authority about potential privacy violations.

Distributed a more comprehensive notice to employees and received their express consent.

Consulted with the Information Security team to weigh security measures against possible server impacts.

Please use the following to answer the next question:

Triangulate Inc. is a multinational company, headquartered in New Jersey with offices throughout the United States, Asia. and Europe (including France, Spain, Sweden and Portugal)_ Last year the company was the victim of a phishing attack that resulted in a significant data breach. The executive board, in coordination with the general manager, their Privacy Office and the Information Security team, resolved to adopt additional security measures. These included training awareness programs, a cybersecurity audit, and use of a new software tool called FirstSecurity, which scans employees' computers to see if they have software that is no longer being supported by a vendor and therefore not getting security updates.

However, this software also provides other features, including the monitoring of employees' computers. Since these measures would potentially impact employees. Triangulate's Privacy Office decided to issue a general notice to all employees indicating that the company will implement a series of initiatives to enhance information security and prevent future data breaches.

After the implementation of these measures, server performance decreased. The general manager instructed the Security team on how to use FirstSecurity to monitor employees' computers activity and their location. During these activities, the Information Security team discovered that one employee from Spain was daily connecting to a video library of movies, and another one from France worked remotely without authorization. The Security team reported these incidents to the Privacy Office and the general manager. In their report, the team concluded that the employee from Spain was the reason why the server performance decreased.

Due to the seriousness of these infringements, the company decided to apply disciplinary measures to both employees, since the security and privacy policy of the company prohibited employees from installing software on the company's computers, and from working remotely without authorization.

9) Under what circumstances would the GDPR apply to personal data that exists in physical form, such as information contained in notebooks or hard copy files?

Only where the personal data is produced as a physical output of specific automated processing activities, such as printing, labelling, or stamping.

Only where the personal data is to be subjected to specific computerized processing, such as image scanning or optical character recognition.

Only where the personal data is treated by automated means in some way, such as computerized distribution or filing.

Only where the personal data is handled in a sufficiently structured manner so as to form part of a filing system.

Please use the following to answer the next question:

Triangulate Inc. is a multinational company, headquartered in New Jersey with offices throughout the United States, Asia. and Europe (including France, Spain, Sweden and Portugal)_ Last year the company was the victim of a phishing attack that resulted in a significant data breach. The executive board, in coordination with the general manager, their Privacy Office and the Information Security team, resolved to adopt additional security measures. These included training awareness programs, a cybersecurity audit, and use of a new software tool called FirstSecurity, which scans employees' computers to see if they have software that is no longer being supported by a vendor and therefore not getting security updates.

However, this software also provides other features, including the monitoring of employees' computers. Since these measures would potentially impact employees. Triangulate's Privacy Office decided to issue a general notice to all employees indicating that the company will implement a series of initiatives to enhance information security and prevent future data breaches.

After the implementation of these measures, server performance decreased. The general manager instructed the Security team on how to use FirstSecurity to monitor employees' computers activity and their location. During these activities, the Information Security team discovered that one employee from Spain was daily connecting to a video library of movies, and another one from France worked remotely without authorization. The Security team reported these incidents to the Privacy Office and the general manager. In their report, the team concluded that the employee from Spain was the reason why the server performance decreased.

Due to the seriousness of these infringements, the company decided to apply disciplinary measures to both employees, since the security and privacy policy of the company prohibited employees from installing software on the company's computers, and from working remotely without authorization.

10) In addition to notifying employees about the purpose of the monitoring, the potential uses of their data and their privacy rights, what information should Triangulate have provided them before implementing the security measures?

Information about what is specified in the employment contract.

Information about who employees should contact with any queries.

Information about how providing consent could affect them as employees.

Information about how the measures are in the best interests of the company.

Please use the following to answer the next question:

Mariam and Rob both work at Hallow College. Mariam is a lawyer responsible for data protection, while Rob is a lecturer in the engineering department. The College maintains a number of types of records:

Student records, including names, student numbers, home addresses, pre-College information, College attendance and performance records, details of special educational needs and financial information
Staff records, including autobiographical materials (such as curricula, professional contact files, student evaluations and other relevant teaching files).
Alumni records, including birthplaces, years of birth, dates of matriculation and conferrals of degrees. These records are available to former students after registering through Hallow’s Alumni portal
Department for Education records, showing how certain demographic groups (such as first-generation students) could be expected, on average, to progress. These records do not contain names or identification numbers.
Under their security policy, the College encrypts all of its personal data records in transit and at rest.

In order to improve his teaching, Rob wants to investigate how his engineering students perform in relational to Department for Education expectations. He has attended one of Mariam's data protection training courses and knows that he should use no more personal data than necessary to accomplish his goal. He creates a program that will only export some student data: previous schools attended, grades originally obtained, grades currently obtained and first time College attended. He wants to keep the records at the individual student level. Mindful of Mariam's training, Rob runs the student numbers through an algorithm to transform them into different reference numbers. He uses the same algorithm on each occasion so that he can update each record over time.

One of Mariam's tasks is to complete the record of processing activities, as required by the GDPR. After receiving her email reminder, Rob informs Mariam about his performance database.

Ann explains to Rob that, as well as minimizing personal data, the College has to check that this new use of existing data is permissible. She also suspects that, under the GDPR, a risk analysis may have to be carried out before the data processing can take place. Mariam arranges to discuss this further with Rob after she has done some additional research.

Rob wants to be able to work on his analysis in his spare time, so he transfers it to his home laptop (which is not encrypted). Unfortunately, when Rob takes the laptop into the College he loses it on the train. Rob has to see Mariam that day to discuss compatible processing. He knows that he needs to report security incidents, so he decides to tell Mariam about his lost laptop at the same time.

11) Mariam will find that a risk analysis is NOT necessary in this situation as long as?

The data subjects are no longer current students of Rob's.

The processing will not negatively affect the rights of the data subjects.

The algorithms that Rob uses for the processing are technologically sound.

The data subjects gave their unambiguous consent for the original processing.

Please use the following to answer the next question:

Mariam and Rob both work at Hallow College. Mariam is a lawyer responsible for data protection, while Rob is a lecturer in the engineering department. The College maintains a number of types of records:

Student records, including names, student numbers, home addresses, pre-College information, College attendance and performance records, details of special educational needs and financial information
Staff records, including autobiographical materials (such as curricula, professional contact files, student evaluations and other relevant teaching files).
Alumni records, including birthplaces, years of birth, dates of matriculation and conferrals of degrees. These records are available to former students after registering through Hallow’s Alumni portal
Department for Education records, showing how certain demographic groups (such as first-generation students) could be expected, on average, to progress. These records do not contain names or identification numbers.
Under their security policy, the College encrypts all of its personal data records in transit and at rest.

In order to improve his teaching, Rob wants to investigate how his engineering students perform in relational to Department for Education expectations. He has attended one of Mariam's data protection training courses and knows that he should use no more personal data than necessary to accomplish his goal. He creates a program that will only export some student data: previous schools attended, grades originally obtained, grades currently obtained and first time College attended. He wants to keep the records at the individual student level. Mindful of Mariam's training, Rob runs the student numbers through an algorithm to transform them into different reference numbers. He uses the same algorithm on each occasion so that he can update each record over time.

One of Mariam's tasks is to complete the record of processing activities, as required by the GDPR. After receiving her email reminder, Rob informs Mariam about his performance database.

Ann explains to Rob that, as well as minimizing personal data, the College has to check that this new use of existing data is permissible. She also suspects that, under the GDPR, a risk analysis may have to be carried out before the data processing can take place. Mariam arranges to discuss this further with Rob after she has done some additional research.

Rob wants to be able to work on his analysis in his spare time, so he transfers it to his home laptop (which is not encrypted). Unfortunately, when Rob takes the laptop into the College he loses it on the train. Rob has to see Mariam that day to discuss compatible processing. He knows that he needs to report security incidents, so he decides to tell Mariam about his lost laptop at the same time.

12) An unforeseen power outage results in company’s lack of access to customer data for six hours. According to article 32 of the GDPR, this is considered a breach. Based on the WP 29's February, 2018 guidance, the company should do which of the following?

Notify' affected individuals that their data was unavailable for a period of time.

Document the loss of availability to demonstrate accountability.

Notify the supervisory authority about the loss of availability.

Conduct a thorough audit of all security systems.

Please use the following to answer the next question:

Mariam and Rob both work at Hallow College. Mariam is a lawyer responsible for data protection, while Rob is a lecturer in the engineering department. The College maintains a number of types of records:

Student records, including names, student numbers, home addresses, pre-College information, College attendance and performance records, details of special educational needs and financial information
Staff records, including autobiographical materials (such as curricula, professional contact files, student evaluations and other relevant teaching files).
Alumni records, including birthplaces, years of birth, dates of matriculation and conferrals of degrees. These records are available to former students after registering through Hallow’s Alumni portal
Department for Education records, showing how certain demographic groups (such as first-generation students) could be expected, on average, to progress. These records do not contain names or identification numbers.
Under their security policy, the College encrypts all of its personal data records in transit and at rest.

In order to improve his teaching, Rob wants to investigate how his engineering students perform in relational to Department for Education expectations. He has attended one of Mariam's data protection training courses and knows that he should use no more personal data than necessary to accomplish his goal. He creates a program that will only export some student data: previous schools attended, grades originally obtained, grades currently obtained and first time College attended. He wants to keep the records at the individual student level. Mindful of Mariam's training, Rob runs the student numbers through an algorithm to transform them into different reference numbers. He uses the same algorithm on each occasion so that he can update each record over time.

One of Mariam's tasks is to complete the record of processing activities, as required by the GDPR. After receiving her email reminder, Rob informs Mariam about his performance database.

Ann explains to Rob that, as well as minimizing personal data, the College has to check that this new use of existing data is permissible. She also suspects that, under the GDPR, a risk analysis may have to be carried out before the data processing can take place. Mariam arranges to discuss this further with Rob after she has done some additional research.

Rob wants to be able to work on his analysis in his spare time, so he transfers it to his home laptop (which is not encrypted). Unfortunately, when Rob takes the laptop into the College he loses it on the train. Rob has to see Mariam that day to discuss compatible processing. He knows that he needs to report security incidents, so he decides to tell Mariam about his lost laptop at the same time.

13) Which of the following does NOT have to be included in the records most processors must maintain in relation to their data processing activities?

Name and contact details of each controller on behalf of which the processor is acting.

Categories of processing carried out on behalf of each controller for which the processor is acting.

Details of transfers of personal data to a third country carried out on behalf of each controller for which the processor is acting.

Details of any data protection impact assessment conducted in relation to any processing activities carried out by the processor on behalf of each controller for which the processor is acting.

Read the following steps:

Discover which employees are accessing cloud services and from which devices and apps
Lock down the data in those apps and devices
Monitor and analyze the apps and devices for compliance
Manage application life cycles
Monitor data sharing

14) An organization should perform these steps to do which of the following?

Pursue a GDPR-compliant Privacy by Design process.

Institute a GDPR-compliant employee monitoring process.

Maintain a secure Bring Your Own Device (BYOD) program.

Ensure cloud vendors are complying with internal data use policies.

Please use the following to answer the next question:

Potters Bar, a golf club, which Micheal has membership has branches across the UK and EU. It’s main establishment is in Spain. Michael resides in Derry, Northern Ireland (part of the U.K.), he travels to work in Lough Foyle, Ireland. During a Potters Bar golf tournament in Stockholm, Sweden Michael gave his consent to being included in a photograph, he was informed that it would be used for promotional purposes only. Since then the photograph has been used in the club's U.K. brochures, and it features in the landing page of its U.K. website. The golf club however has gained some notoriety as a result to ill treatment of members at several branches of the club in other EU member states. Due to this Michael no longer feels comfortable with his photograph being publicly associated with the golf club.

Michael's attempts to make an appointment and discuss the issue with his local branch manager was unsuccessful. He then makes a written request to Potters Bar in a bid that his image be pulled down from the website and all forms of publicity. Several months went by and Potters Bar failed to address Michael’s request which led him to become quite concerned and prompted him to take action.

15) Michael contacts the U.K. Information Commissioner's Office ('ICO' — the UK's supervisory authority) to lodge a complaint about this matter. Under the cooperation mechanism, what should the lead authority (AEPD) do after it has formed its view on the matter?

Submit a draft decision to other supervisory authorities for their opinion.

Request that the other supervisory authorities provide the lead authority with a draft decision for its consideration.

Submit a draft decision directly to the Commission to ensure the effectiveness of the consistency mechanism.

Request that members of the seconding supervisory authority and the host supervisory authority co-draft a decision.

Please use the following to answer the next question:

Potters Bar, a golf club, which Micheal has membership has branches across the UK and EU. It’s main establishment is in Spain. Michael resides in Derry, Northern Ireland (part of the U.K.), he travels to work in Lough Foyle, Ireland. During a Potters Bar golf tournament in Stockholm, Sweden Michael gave his consent to being included in a photograph, he was informed that it would be used for promotional purposes only. Since then the photograph has been used in the club's U.K. brochures, and it features in the landing page of its U.K. website. The golf club however has gained some notoriety as a result to ill treatment of members at several branches of the club in other EU member states. Due to this Michael no longer feels comfortable with his photograph being publicly associated with the golf club.

Michael's attempts to make an appointment and discuss the issue with his local branch manager was unsuccessful. He then makes a written request to Potters Bar in a bid that his image be pulled down from the website and all forms of publicity. Several months went by and Potters Bar failed to address Michael’s request which led him to become quite concerned and prompted him to take action.

16) Assuming that multiple Potters Bar branches across several EU countries are acting as separate data controllers, and that each of those branches were responsible for mishandling Michael's request, how may Michael proceed in order to seek compensation?

He will have to sue Potters Bar’s head office in Spain, where Potters Bar's has its main establishment.

He will be able to sue any one of the relevant Potters Bar branches, as each one may be held liable for the entire damage.

He will have to sue each Potters Bar's branch so that each branch provides proportionate compensation commensurate with its contribution to the damage or distress suffered by Ben.

He will be able to apply to the European Data Protection Board in order to determine which particular Potters Bar branch is liable for damages, based on the decision that was made by the board.

Please use the following to answer the next question:

Potters Bar, a golf club, which Micheal has membership has branches across the UK and EU. It’s main establishment is in Spain. Michael resides in Derry, Northern Ireland (part of the U.K.), he travels to work in Lough Foyle, Ireland. During a Potters Bar golf tournament in Stockholm, Sweden Michael gave his consent to being included in a photograph, he was informed that it would be used for promotional purposes only. Since then the photograph has been used in the club's U.K. brochures, and it features in the landing page of its U.K. website. The golf club however has gained some notoriety as a result to ill treatment of members at several branches of the club in other EU member states. Due to this Michael no longer feels comfortable with his photograph being publicly associated with the golf club.

Michael's attempts to make an appointment and discuss the issue with his local branch manager was unsuccessful. He then makes a written request to Potters Bar in a bid that his image be pulled down from the website and all forms of publicity. Several months went by and Potters Bar failed to address Michael’s request which led him to become quite concerned and prompted him to take action.

17) In addition to the European Commission, who can adopt standard contractual clauses, assuming that all required conditions are met?

Approved data controllers.

The Council of the European Union.

National data protection authorities.

The European Data Protection Supervisor.

Please use the following to answer the next question:

Zoro, an online retailer known for its environmentally friendly shoes, has recently expanded its presence in Europe- Anxious to achieve market dominance, Zoro teamed up with another eco friendly company, TeraWorld, which sells accessories like belts and bags. Together the companies drew up a series of marketing campaigns designed to highlight the environmental and economic benefits of their products. After months of planning, Zoro and TeraWorld entered into a data sharing agreement to use the same marketing database, PromoChimp, to send the campaigns to their respective contacts.

Zoro and TeraWorld also entered into a data processing agreement with PromoChimp, the terms of which included processing personal data only upon Liern and TeraWorld's instructions, and making available to them all information necessary to demonstrate compliance with GDPR obligations.

Zoro and TeraWorld then procured the services of a company called E-List. a marketing optimization firm that uses machine learning to help companies run successful campaigns. Clients provide E-List with the personal data of individuals they would like to be targeted in each campaign. To ensure protection of its clients' data. E-List implements the technical and organizational measures it deems appropriate- E-List works to continually improve its machine leaming models by analyzing the data it receives from its clients to determine the most successful components of a successful campaign. E-List then uses such models in providing services to its client-base. Since the models improve only over a period of time as more information is collected, E-List does not have a deletion process for the data it receives from clients. However, to ensure compliance with data privacy rules, E-List pseudonymizes the personal data by removing identing information from the contact information E-List's engineers, however, maintain all contact information in the same database as the identifying information.

Under its agreement with Zoro and TeraWorld, E-List received access to PromoChimp, which included contact information as well as prior purchase history for such contacts, to create campaigns that would result in the most Views of the two companies' websites. A prior Zoro customer, Mr Paige, received a marketing campaign from E-List regarding Zoro's as well as TeraWorld's latest products. While Mr Paige recalls checking a box to receive information in the future regarding Zoro's products, he has never shopped TeraWorld, nor provided his personal data to that company.

18) Why would the consent provided by Mr Paige NOT be considered valid in regard to E-List?

He was not told which controller would be processing his personal data.

He only viewed the visual representations of the privacy notice Zoro provided.

He did not read the privacy notice stating that his personal data would be shared.

He has never made any purchases from E-List and has no relationship with the company.

Please use the following to answer the next question:

Zoro, an online retailer known for its environmentally friendly shoes, has recently expanded its presence in Europe- Anxious to achieve market dominance, Zoro teamed up with another eco friendly company, TeraWorld, which sells accessories like belts and bags. Together the companies drew up a series of marketing campaigns designed to highlight the environmental and economic benefits of their products. After months of planning, Zoro and TeraWorld entered into a data sharing agreement to use the same marketing database, PromoChimp, to send the campaigns to their respective contacts.

Zoro and TeraWorld also entered into a data processing agreement with PromoChimp, the terms of which included processing personal data only upon Liern and TeraWorld's instructions, and making available to them all information necessary to demonstrate compliance with GDPR obligations.

Zoro and TeraWorld then procured the services of a company called E-List. a marketing optimization firm that uses machine learning to help companies run successful campaigns. Clients provide E-List with the personal data of individuals they would like to be targeted in each campaign. To ensure protection of its clients' data. E-List implements the technical and organizational measures it deems appropriate- E-List works to continually improve its machine leaming models by analyzing the data it receives from its clients to determine the most successful components of a successful campaign. E-List then uses such models in providing services to its client-base. Since the models improve only over a period of time as more information is collected, E-List does not have a deletion process for the data it receives from clients. However, to ensure compliance with data privacy rules, E-List pseudonymizes the personal data by removing identing information from the contact information E-List's engineers, however, maintain all contact information in the same database as the identifying information.

Under its agreement with Zoro and TeraWorld, E-List received access to PromoChimp, which included contact information as well as prior purchase history for such contacts, to create campaigns that would result in the most Views of the two companies' websites. A prior Zoro customer, Mr Paige, received a marketing campaign from E-List regarding Zoro's as well as TeraWorld's latest products. While Mr Paige recalls checking a box to receive information in the future regarding Zoro's products, he has never shopped TeraWorld, nor provided his personal data to that company.

19) Under the GDPR, Zoro and TeraWorld's contract with PromoChimp must include all of the following provisions EXCEPT?

Processing the personal data upon documented instructions regarding data transfers outside of the EEA .

Notification regarding third party requests for access to Zoro and TeraWorld's personal data.

Assistance to Zoro and TeraWorld's in their compliance with data protection impact assessments.

Returning or deleting personal data after the end of the provision of the services.

20) Under the GDPR, who would be LEAST likely to be allowed to engage in the collection, use, and disclosure of a data subject's sensitive medical information without the data subject's knowledge or consent?

A member of the judiciary involved in adjudicating a legal dispute involving the data subject and concerning the health of the data subject.

A public authority responsible for public health, where the sharing of such information is considered necessary for the protection of the general populace.

A health professional involved in the medical care for the data subject, where the data subject's life hinges on the timely dissemination of such information.

A journalist writing an article relating to the medical condition in question, who believes that the publication of such information is in the public interest.

21)What is true of both the General Data Protection Regulation (GDPR) and the Council of Europe Convention 108?

Both govern international transfers of personal data.

Both govern the manual processing of personal data.

Both only apply to European Union countries.

Both require notification of processing activities to a supervisory authority.

22) In which of the following cases would an organization MOST LIKELY be required to follow both ePrivacy and data protection rules?

When creating an untargeted pop-up ad on a website.

When calling a potential customer to notify her of an upcoming product sale.

When emailing a customer to announce that his recent order should arrive earlier than expected.

When paying a search engine company to give prominence to certain products and services within specific search results.

Please use the following to answer the next question:

ABC World is a successful international online toy shop that employs approximately 900 people at its headquarters based in France. Julien is their recently appointed data protection officer, who oversees the company's compliance with the General Data Protection Regulation (GDPR) and other privacy legislation. The company offers both toys and gadgets for male and female across all age demographics, including adults. In doing so, the company processes large amounts of information about such customers, including preferences and sensitive financial information such as credit card and bank account numbers.

In an aggressive bid to build revenue growth, Matt, the CIO, tells Julien that the company is launching a new mobile app and loyalty scheme that puts significant emphasis on profiling the company’s customers by analyzing their purchases. Julien tells the CIO that: (a) the potential risks of such activities means that ABC World needs to carry out a data protection impact assessment to assess this new venture and its privacy implications: and (b) where the results of this assessment indicate a high risk in the absence of appropriate protection measures, ABC World may have to undertake a prior consultation with the CNIL, the French Data Protection Commissioner before implementing the app and loyalty scheme.

Matt tells Julien that he is not happy about the prospect of having to directly engage with a supervisory authority and having to disclose details of ABC World's business plan and associated processing activities.

23) What would MOST effectively assist ABC World in conducting their data protection impact assessment?

Information about DPIAs found in Articles 38 through 40 of the GDPR.

Data breach documentation that data controllers are required to maintain.

Existing DPIA guides published by local supervisory authorities.

Records of processing activities that data controllers are required to maintain.

Please use the following to answer the next question:

ABC World is a successful international online toy shop that employs approximately 900 people at its headquarters based in France. Julien is their recently appointed data protection officer, who oversees the company's compliance with the General Data Protection Regulation (GDPR) and other privacy legislation. The company offers both toys and gadgets for male and female across all age demographics, including adults. In doing so, the company processes large amounts of information about such customers, including preferences and sensitive financial information such as credit card and bank account numbers.

In an aggressive bid to build revenue growth, Matt, the CIO, tells Julien that the company is launching a new mobile app and loyalty scheme that puts significant emphasis on profiling the company’s customers by analyzing their purchases. Julien tells the CIO that: (a) the potential risks of such activities means that ABC World needs to carry out a data protection impact assessment to assess this new venture and its privacy implications: and (b) where the results of this assessment indicate a high risk in the absence of appropriate protection measures, ABC World may have to undertake a prior consultation with the CNIL, the French Data Protection Commissioner before implementing the app and loyalty scheme.

Matt tells Julien that he is not happy about the prospect of having to directly engage with a supervisory authority and having to disclose details of ABC World's business plan and associated processing activities.

24) What must ABC World provide to the supervisory authority during the prior consultation?

An evaluation of the complexity of the intended processing.

An explanation of the purposes and means of the intended processing.

Records showing that customers have explicitly consented to the intended profiling activities.

Certificates that prove Julien's professional qualities and expert knowledge of data protection law.

Please use the following to answer the next question:

You have just been hired by a toy manufacturer based in Indonesia. The company sells a broad range of action figures and dolls that can be found internationally in a wide variety of retail stores. Although the manufacturer has no offices outside Indonesia and in fact does not employ any staff outside Indonesia, it has entered into a number of local distribution contracts. The toys produced by the company can be found in all popular toy stores throughout Europe, the United States and Asia. A large portion of the company's revenue is due to international sales.

The company now wishes to launch a new range of connected toys. ones that can talk and interact with children. The CEO of the company is touting these toys as the next big thing. due to the increased possibilities offered: The figures can answer children's questions on various subjects, such as mathematical calculations or the weather. Each figure is equipped with a microphone and speaker and can connect to any smartphone or tablet via Bluetooth. Any mobile device within a 10-meter radius can connect to the toys via Bluetooth as well. The figures can also be associated with other figures (from the same manufacturer) and interact with each other for an enhanced play experience.

When a child asks the toy a question. the request is sent to the cloud for analysis, and the answer is generated on cloud servers and sent back to the figure. The answer is given through the figure's integrated speakers. making it appear as though that the toy is actually responding to the child's question. The packaging of the toy does not provide technical details on how this works, nor does it mention that this feature requires an internet connection. The necessary data processing for this has been outsourced to a data center located in Russia. However, your company has not yet revised its consumer-facing privacy policy to indicate this.

In parallel. the company is planning to introduce a new range of game systems through which consumers can play the characters they acquire in the course of playing the game. The system will come bundled with a portal that includes a Near-Field Communications (NFC) reader. This device will read an RFID tag in the action figure, making the figure come to life on screen. Each character has its own stock features and abilities, but it is also possible to earn additional ones by accomplishing game goals. The only information stored in the tag relates to the figures' abilities. It is easy to switch characters during the game, and it is possible to bring the figure to locations outside of the home and have the character's abilities remain intact.

25) In light of the requirements of Article 32 of the GDPR (related to the Security of Processing), which practice should the company institute?

Encrypt the data in transit over the wireless Bluetooth connection.

Include dual-factor authentication before each use by a child in order to ensure a minimum amount of security.

Include three-factor authentication before each use by a child in order to ensure the best level of security possible.

Insert contractual clauses into the contract between the toy manufacturer and the cloud service provider, since Russia is outside the European Union.

Please use the following to answer the next question:

You have just been hired by a toy manufacturer based in Indonesia. The company sells a broad range of action figures and dolls that can be found internationally in a wide variety of retail stores. Although the manufacturer has no offices outside Indonesia and in fact does not employ any staff outside Indonesia, it has entered into a number of local distribution contracts. The toys produced by the company can be found in all popular toy stores throughout Europe, the United States and Asia. A large portion of the company's revenue is due to international sales.

The company now wishes to launch a new range of connected toys. ones that can talk and interact with children. The CEO of the company is touting these toys as the next big thing. due to the increased possibilities offered: The figures can answer children's questions on various subjects, such as mathematical calculations or the weather. Each figure is equipped with a microphone and speaker and can connect to any smartphone or tablet via Bluetooth. Any mobile device within a 10-meter radius can connect to the toys via Bluetooth as well. The figures can also be associated with other figures (from the same manufacturer) and interact with each other for an enhanced play experience.

When a child asks the toy a question. the request is sent to the cloud for analysis, and the answer is generated on cloud servers and sent back to the figure. The answer is given through the figure's integrated speakers. making it appear as though that the toy is actually responding to the child's question. The packaging of the toy does not provide technical details on how this works, nor does it mention that this feature requires an internet connection. The necessary data processing for this has been outsourced to a data center located in Russia. However, your company has not yet revised its consumer-facing privacy policy to indicate this.

In parallel. the company is planning to introduce a new range of game systems through which consumers can play the characters they acquire in the course of playing the game. The system will come bundled with a portal that includes a Near-Field Communications (NFC) reader. This device will read an RFID tag in the action figure, making the figure come to life on screen. Each character has its own stock features and abilities, but it is also possible to earn additional ones by accomplishing game goals. The only information stored in the tag relates to the figures' abilities. It is easy to switch characters during the game, and it is possible to bring the figure to locations outside of the home and have the character's abilities remain intact.

26) To ensure GDPR compliance, what should be the company's position on the issue of consent?

The child, as the user of the action figure, can provide consent himself, as long as no information is shared for marketing purposes.

Written authorization attesting to the responsible use of children's data would need to be obtained from the supervisory authority.

Consent for data collection is implied through the parent's purchase of the action figure for the child.

Parental consent for a child's use of the action figures would have to be obtained before any data could be collected.

27) Why is it advisable to avoid consent as a legal basis for an employer to process employee data?

Employee data can only be processed if there is an approval from the data protection officer.

Consent may not be valid if the employee feels compelled to provide it.

An employer might have difficulty obtaining consent from every employee

Data protection laws do not apply to processing of employee data.

Please use the following to answer the next question:

Greg, a long-time customer of XERO insurance, was involved in a minor car accident a few months ago. Although no one was hurt, Greg has been plagued by texts and calls from a company called Mobo Insurance offering to help him recover compensation for personal injury Greg has heard about insurance companies selling customers' data to third parties, and he's convinced that Mobo must have gotten his information from XERO.

Greg has also been receiving an increased amount of marketing information from XERO, trying to sell him their full range of their insurance policies.

Perturbed by this, Greg has started looking at price comparison sites on the Internet and has been shocked to find that other insurers offer much cheaper rates than XERO, even though he has been a loyal customer for many years. When his XERO policy comes up for renewal. he decides to switch to Alliance Insurance. In order to activate his new insurance policy, Greg needs to supply Alliance with information about his No Claims bonus. his vehicle and his driving history. After researching his rights under the GDPR, he writes to ask XERO to transfer his information directly to Alliance. He also takes this opportunity to ask XERO to stop using his personal data for marketing purposes.

XERO supplies Greg with a PDF and XML (Extensible Markup Language) versions of his No Claims Certificate, but tells Greg it cannot transfer his data directly to Alliance at this is not technically feasible. XERO also explains that Greg's contract included a provision whereby Greg agreed that his data could be used for marketing purposes; according to XERO, it is too late for Greg to change his mind about this. It angers Greg when he recalls the wording of the contract, which was filled with legal Jargon and very confusing. In the meantime, Greg is still receiving unwanted calls from Mobo Insurance. He writes to Mobo to ask for the name of the organization that supplied his details to them. He warns Mobo that he plans to complain to the data protection authority because he thinks their company has been using his data unlawfully. His letter states that he does not want his data being used by them in any way.

Mobo's response letter confirms Greg's suspicions. Mobo is XERO's wholly owned subsidiary, and they received information about Greg's accident from XERO shortly after Greg submitted his accident claim. Mobo assures Greg that there has been no breach of the GDPR, as Greg's contract included a provision in which he agreed to share his information with XERO's affiliates for business purposes.

Greg is disgusted by the way in which he has been treated by XERO, and writes to them insisting that all his information be erased from their computer system.

28) After Greg has exercised his right to restrict the use of his data, under what conditions would Mobo have grounds for refusing to comply?

If Mobo is entitled to use of the data as an affiliate of XERO.

If Mobo also uses the data to conduct public health research.

If the data becomes necessary to defend Mobo's legal rights.

If the accuracy of the data is not an aspect that Greg is disputing.

Please use the following to answer the next question:

Greg, a long-time customer of XERO insurance, was involved in a minor car accident a few months ago. Although no one was hurt, Greg has been plagued by texts and calls from a company called Mobo Insurance offering to help him recover compensation for personal injury Greg has heard about insurance companies selling customers' data to third parties, and he's convinced that Mobo must have gotten his information from XERO.

Greg has also been receiving an increased amount of marketing information from XERO, trying to sell him their full range of their insurance policies.

Perturbed by this, Greg has started looking at price comparison sites on the Internet and has been shocked to find that other insurers offer much cheaper rates than XERO, even though he has been a loyal customer for many years. When his XERO policy comes up for renewal. he decides to switch to Alliance Insurance. In order to activate his new insurance policy, Greg needs to supply Alliance with information about his No Claims bonus. his vehicle and his driving history. After researching his rights under the GDPR, he writes to ask XERO to transfer his information directly to Alliance. He also takes this opportunity to ask XERO to stop using his personal data for marketing purposes.

XERO supplies Greg with a PDF and XML (Extensible Markup Language) versions of his No Claims Certificate, but tells Greg it cannot transfer his data directly to Alliance at this is not technically feasible. XERO also explains that Greg's contract included a provision whereby Greg agreed that his data could be used for marketing purposes; according to XERO, it is too late for Greg to change his mind about this. It angers Greg when he recalls the wording of the contract, which was filled with legal Jargon and very confusing. In the meantime, Greg is still receiving unwanted calls from Mobo Insurance. He writes to Mobo to ask for the name of the organization that supplied his details to them. He warns Mobo that he plans to complain to the data protection authority because he thinks their company has been using his data unlawfully. His letter states that he does not want his data being used by them in any way.

Mobo's response letter confirms Greg's suspicions. Mobo is XERO's wholly owned subsidiary, and they received information about Greg's accident from XERO shortly after Greg submitted his accident claim. Mobo assures Greg that there has been no breach of the GDPR, as Greg's contract included a provision in which he agreed to share his information with XERO's affiliates for business purposes.

Greg is disgusted by the way in which he has been treated by XERO, and writes to them insisting that all his information be erased from their computer system.

29) What is one major goal that the OECD Guidelines, Convention 108 and the Data Protection Directive (Directive 95/46/EC) all had in common but largely failed to achieve in Europe?

The establishment of a list of legitimate data processing criteria.

The creation of legally binding data protection principles.

The synchronization of approaches to data protection.

The restriction of cross-border data flow.

30) A mobile device application that uses cookies will be subject to the consent requirement of which of the following?

The ePrivacy Directive.

The E-Commerce Directive.

The Data Retention Directive.

The EU Cybersecurity Directive.

31) What is the MAIN reason GDPR Article 4(22) establishes the concept of the concerned supervisory authority'?

To encourage the consistency of local data processing activity.

To give corporations a choice about who their supervisory authority will be.

To ensure the GDPR covers controllers that do not have an establishment in the EU but have a representative in a member state.

To ensure that the interests of individuals residing outside the lead authority's jurisdiction are represented.

Please use the following to answer the next question:

Zoro, an online retailer known for its environmentally friendly shoes, has recently expanded its presence in Europe- Anxious to achieve market dominance, Zoro teamed up with another eco friendly company, TeraWorld, which sells accessories like belts and bags. Together the companies drew up a series of marketing campaigns designed to highlight the environmental and economic benefits of their products. After months of planning, Zoro and TeraWorld entered into a data sharing agreement to use the same marketing database, PromoChimp, to send the campaigns to their respective contacts.

Zoro and TeraWorld also entered into a data processing agreement with PromoChimp, the terms of which included processing personal data only upon Liern and TeraWorld's instructions, and making available to them all information necessary to demonstrate compliance with GDPR obligations.

Zoro and TeraWorld then procured the services of a company called E-List. a marketing optimization firm that uses machine learning to help companies run successful campaigns. Clients provide E-List with the personal data of individuals they would like to be targeted in each campaign. To ensure protection of its clients' data. E-List implements the technical and organizational measures it deems appropriate- E-List works to continually improve its machine leaming models by analyzing the data it receives from its clients to determine the most successful components of a successful campaign. E-List then uses such models in providing services to its client-base. Since the models improve only over a period of time as more information is collected, E-List does not have a deletion process for the data it receives from clients. However, to ensure compliance with data privacy rules, E-List pseudonymizes the personal data by removing identing information from the contact information E-List's engineers, however, maintain all contact information in the same database as the identifying information.

Under its agreement with Zoro and TeraWorld, E-List received access to PromoChimp, which included contact information as well as prior purchase history for such contacts, to create campaigns that would result in the most Views of the two companies' websites. A prior Zoro customer, Mr Paige, received a marketing campaign from E-List regarding Zoro's as well as TeraWorld's latest products. While Mr Paige recalls checking a box to receive information in the future regarding Zoro's products, he has never shopped TeraWorld, nor provided his personal data to that company.

32) E-List's use of pseudonymization is NOT in compliance with the GDPR because?

E-List failed to first anonymize the personal data.

E-List pseudonymized all the data instead of deleting what it no longer needed.

E-List was in possession of information that could be used to identify data subjects.

E-List failed to keep personally identifiable information in a separate database.

Please use the following to answer the next question:

Zoro, an online retailer known for its environmentally friendly shoes, has recently expanded its presence in Europe- Anxious to achieve market dominance, Zoro teamed up with another eco friendly company, TeraWorld, which sells accessories like belts and bags. Together the companies drew up a series of marketing campaigns designed to highlight the environmental and economic benefits of their products. After months of planning, Zoro and TeraWorld entered into a data sharing agreement to use the same marketing database, PromoChimp, to send the campaigns to their respective contacts.

Zoro and TeraWorld also entered into a data processing agreement with PromoChimp, the terms of which included processing personal data only upon Liern and TeraWorld's instructions, and making available to them all information necessary to demonstrate compliance with GDPR obligations.

Zoro and TeraWorld then procured the services of a company called E-List. a marketing optimization firm that uses machine learning to help companies run successful campaigns. Clients provide E-List with the personal data of individuals they would like to be targeted in each campaign. To ensure protection of its clients' data. E-List implements the technical and organizational measures it deems appropriate- E-List works to continually improve its machine leaming models by analyzing the data it receives from its clients to determine the most successful components of a successful campaign. E-List then uses such models in providing services to its client-base. Since the models improve only over a period of time as more information is collected, E-List does not have a deletion process for the data it receives from clients. However, to ensure compliance with data privacy rules, E-List pseudonymizes the personal data by removing identing information from the contact information E-List's engineers, however, maintain all contact information in the same database as the identifying information.

Under its agreement with Zoro and TeraWorld, E-List received access to PromoChimp, which included contact information as well as prior purchase history for such contacts, to create campaigns that would result in the most Views of the two companies' websites. A prior Zoro customer, Mr Paige, received a marketing campaign from E-List regarding Zoro's as well as TeraWorld's latest products. While Mr Paige recalls checking a box to receive information in the future regarding Zoro's products, he has never shopped TeraWorld, nor provided his personal data to that company.

33) For what reason would E-List be considered a controller under the GDPR?

It determines how long to retain the personal data collected.

It has been provided access to personal data in the PromoChimp database.

It uses personal data to improve its products and services for its client-base through machine learning.

It makes decisions regarding the technical and organizational measures necessary to protect the personal data.

34) What permissions are required for a marketer to send an email marketing message to a consumer in the EU?

A prior opt-in consent for consumers unless they are already customers.

A pre-checked box stating that the consumer agrees to receive email marketing.

A notice that the consumers email address will be used for marketing purposes.

No prior permission required, but an opt-out requirement on all emails sent to consumers.

35) If a multi-national company wanted to conduct background checks on all current and potential employees, including those based in Europe, what key provision would the company have to follow?

Background checks on employees could be performed only under prior notice to all employees.

Background checks are only authorized with prior notice and express consent from all employees including those based in Europe.

Background checks on European employees will stem from data protection and employment law, which can vary between member states.

Background checks may not be allowed on European employees, but the company can create lists based on its legitimate interests, identifying individuals who are ineligible for employment.

36) Under Article 21 of the GDPR, a controller must stop profiling when requested by a data subject, unless it can demonstrate compelling legitimate grounds that override the interests of the individual. In the Guidelines on Automated individual decision-making and Profiling, the WP 29 says the controller needs to do all of the following to demonstrate that it has such legitimate grounds EXCEPT?

Carry out an exercise that weighs the interests of the controller and the basis for the data subject's objection.

Consider the impact of the profiling on the data subject's interest, rights and freedoms.

Demonstrate that the profiling is for the purposes of direct marketing.

Consider the importance of the profiling to their particular objective.

37) Which of the following would require designating a data protection officer?

Processing is carried out by an organization employing 250 persons or more.

Processing is carried out for the purpose of providing for-profit goods or services to individuals in the EU.

The core activities of the controller or processor consist of processing operations of financial information or information relating to children.

The core activities of the controller or processor consist of processing operations that require systematic monitoring of data subjects on a large scale.

38) How does the GDPR now define processing'?

Any act involving the collecting and recording of personal data.

Any operation or set of operations performed on personal data or on sets of personal data.

Any use or disclosure of personal data compatible with the purpose for which the data was collected.

Any operation or set of operations performed by automated means on personal data or on sets of personal data.

39) The GDPR specifies fines that may be levied against data controllers for certain infringements. Which of the following infringements would be subject to the less severe administrative fine of up to 10 million euros (or in the case of an undertaking, up to 2% of the total worldwide annual turnover of the preceding financial year)?

Failure to demonstrate that consent was given by the data subject to the processing of their personal data where it is used as the basis for processing.

Failure to implement technical and organizational measures to ensure data protection is enshrined by design and default.

Failure to process personal information in a manner compatible with its original purpose.

Failure to provide the means for a data subject to rectify inaccuracies in personal data.

40) Assuming that the without undue delay' provision is followed, what is the time limit for complying with a data access request?

Within 40 days of receipt.

Within 40 days of receipt, which may be extended by up to 40 additional days.

Within one month of receipt, which may be extended by up to an additional month.

Within one month of receipt, which may be extended by an additional two months.

41) Which of the following describes a mandatory requirement for a group of undertakings that wants to appoint a single data protection officer?

The group of undertakings must obtain approval from a supervisory authority.

The group of undertakings must be comprised of organizations of similar sizes and functions.

The data protection officer must be located in the country where the data controller has its main establishment.

The data protection officer must be easily accessible from each establishment where the undertakings are located.

42) Which of the following BEST described the EU Data Protection Model?

Co-Regulatory

Comprehensive

Self-Regulatory

Sectorial

43) Based on GDPR Article 35, which of the following situations would trigger the need to complete a DPIA?

A company wants to build a dating app that creates candidate profiles based on location data and data from third-party sources.

A company wants to combine location data with other data in order to offer more personalized service for the customer.

A company wants to use location data to infer information on a person’s clothes purchasing habits.

A company wants to use location data to track delivery trucks in order to make the routes more efficient.

44) Which of the following controller/processing scenarios in principle CAN use the Public Interest legal basis?

A vehicle licensing agency selling owner names and contact details to the private sector in exchange for money

A company director credit checking agency republishing the contents of a Mandatory Public Register of directors which is already in the public domain publishing the names and addresses of directors on the internet

A registered and regulated charity receiving information from any public sector body as part of a lawful Data Sharing Agreement

None of the above

45) Where the data subject is a child, what steps must controllers take in respect of consent, within the constraints of available technology?

Controllers must make best efforts to verify the consent.

Controllers must make reasonable efforts to verify the consent.

Controllers must make best efforts to request the consent in clear and plain language, in the context of the age of the child.

Controllers must make reasonable efforts to request the consent in clear and plain language, in the context of the age of the child.

46) Under the GDPR in which of the following situations are there derogations, where each member state can make adjustment to their national laws.

The default age at which a child can give consent.

The usefulness of the Principle of fairness, lawfulness and transparency.

The right to erasure.

All of the above.

47) Which of the following is NOT categorically one of the types of Privacy?

Intellectual Privacy

Information Privacy

Bodily Privacy

Territorial Privacy

48) While implementing certain data subject rights the controller is obliged by Article 19 to inform each third party recipient of the personal data. For which of the following rights does this apply?

Restriction under Article 18

Rectification under Article 16

Erasure / "right to be forgotten" under Article 17

All of the above

Please use the following to answer the next question:

An individual drops their business card into a prize draw box in a coffee shop. This is an affirmative act that clearly indicates they agree to their name and contact number being processed for the purposes of the prize draw. However, this consent does not extend to using those details for marketing BUT the coffee shop has used the details to send out Christmas Promotions and vouchers.

49) The act of the coffee shop is in violation of which of the GDPR Principles?

Purpose Limitation

Data Minimisation

Data Accuracy

None of the above

Please use the following to answer the next question:

An individual drops their business card into a prize draw box in a coffee shop. This is an affirmative act that clearly indicates they agree to their name and contact number being processed for the purposes of the prize draw. However, this consent does not extend to using those details for marketing BUT the coffee shop has used the details to send out Christmas Promotions and vouchers.

50) The violation of the GDPR Principle(s) may lead to a penalty of what?

up to 20 million euros, or in the case of an undertaking, up to 4 % of their total global turnover of the preceding fiscal year, whichever is higher.

up to 10 million euros, or in the case of an undertaking, up to 2 % of their total global turnover of the preceding fiscal year, whichever is higher.

up to 5 million euros, or in the case of an undertaking, up to 1 % of their total global turnover of the preceding fiscal year, whichever is higher.

none of the above