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NEW QUESTION # 77
Scenario7:
Scenario 7: EduCCS is an online education platform based in Netherlands. EduCCS helps organizations find, manage, and deliver their corporate training. Most of EduCCS's clients are EU residents. EduCCS is one of the few education organizations that have achieved GDPR compliance since 2019. Their DPO is a full-time employee who has been engaged in most data protection processes within the organization. In addition to facilitating GDPR compliance, the DPO acts as an intermediary point between EduCCS and other relevant interested parties. EduCCS's users can benefit from the variety of up-to-date training library and the possibility of accessing it through their phones, tablets, or computers. EduCCS's services are offered through two main platforms: online learning and digital training. To use one of these platforms, users should sign on EduCCS's website by providing their personal information. Online learning is a platform in which employees of other organizations can search for and request the training they need. Through its digital training platform, on the other hand, EduCCS manages the entire training and education program for other organizations.
Organizations that need this type of service need to provide information about their core activities and areas where training sessions are needed. This information is then analyzed by EduCCS and a customized training program is provided. In the beginning, all IT-related services were managed by two employees of EduCCS.
However, after acquiring a large number of clients, managing these services became challenging That is why EduCCS decided to outsource the IT service function to X-Tech. X-Tech provides IT support and is responsible for ensuring the security of EduCCS's network and systems. In addition, X-Tech stores and archives EduCCS's information including their training programs and clients' and employees' data. Recently, X-Tech made headlines in the technology press for being a victim of a phishing attack. A group of three attackers hacked X-Tech's systems via a phishing campaign which targeted the employees of the Marketing Department. By compromising X-Tech's mail server, hackers were able to gain access to more than 200 computer systems. Consequently, access to the networks of EduCCS's clients was also allowed. Using EduCCS's employee accounts, attackers installed a remote access tool on EduCCS's compromised systems.
By doing so, they gained access to personal information of EduCCS's clients, training programs, and other information stored in its online payment system. The attack was detected by X-Tech's system administrator.
After detecting unusual activity in X-Tech's network, they immediately reported it to the incident management team of the company. One week after being notified about the personal data breach, EduCCS communicated the incident to the supervisory authority with a document that outlined the reasons for the delay revealing that due to the lack of regular testing or modification, their incident response plan was not adequately prepared to handle such an attack.Based on this scenario, answer the following question:
Question:
Which of the followingstatements best reflects a lesson learnedfrom the scenario?
Answer: C
Explanation:
UnderArticle 32 and Article 33 of GDPR, organizations mustimplement security measuresand ensure incident response plans are regularly tested and updated.EduCCS' failure to prepare its response plan delayed notification, violating GDPR's72-hour breach notification requirement.
* Option C is correctbecauseregular testing of incident response plans helps prevent delays in breach notifications.
* Option A is incorrectbecause while timely communication is important, theroot issue was the lack of preparedness.
* Option B is incorrectbecauseoutsourcing is allowed under GDPRif the controller ensures compliance through aData Processing Agreement (DPA) (Article 28).
* Option D is incorrectbecauseEduCCS remains responsiblefor data protection, even when outsourcing to a processor.
References:
* GDPR Article 32(1)(d)(Regular testing of security measures)
* GDPR Article 33(1)(72-hour breach notification requirement)
NEW QUESTION # 78
Scenario6:
Bus Spot is one of the largest bus operators in Spain. The company operates in local transport and bus rental since 2009. The success of Bus Spot can be attributed to the digitization of the bus ticketing system, through which clients can easily book tickets and stay up to date on any changes to their arrival or departure time. In recent years, due to the large number of passengers transporteddaily. Bus Spot has dealt with different incidents including vandalism, assaults on staff, and fraudulent injury claims. Considering the severity of these incidents, the need for having strong security measures had become crucial. Last month, the company decided to install a CCTV system across its network of buses. This security measure was taken to monitor the behavior of the company's employees and passengers, enabling crime prevention and ensuring safety and security. Following this decision, Bus Spot initiated a data protection impact assessment (DPIA). The outcome of each step of the DPIA was documented as follows: Step 1: In all 150 buses, two CCTV cameras will be installed. Only individuals authorized by Bus Spot will have access to the information generated by the CCTV system. CCTV cameras capture images only when the Bus Spot's buses are being used. The CCTV cameras will record images and sound. The information is transmitted to a video recorder and stored for 20 days. In case of incidents, CCTV recordings may be stored for more than 40 days and disclosed to a law enforcement body. Data collected through the CCTV system will be processed bv another organization. The purpose of processing this tvoe of information is to increase the security and safety of individuals and prevent criminal activity. Step 2: All employees of Bus Spot were informed for the installation of a CCTV system. As the data controller, Bus Spot will have the ultimate responsibility to conduct the DPIA. Appointing a DPO at that point was deemed unnecessary. However, the data processor's suggestions regarding the CCTV installation were taken into account. Step 3: Risk Likelihood (Unlikely, Possible, Likely) Severity (Moderate, Severe, Critical) Overall risk (Low, Medium, High) There is a risk that the principle of lawfulness, fairness, and transparency will be compromised since individuals might not be aware of the CCTV location and its field of view. Likely Moderate Low There is a risk that the principle of integrity and confidentiality may be compromised in case the CCTV system is not monitored and controlled with adequate security measures.
Possible Severe Medium There is a risk related to the right of individuals to be informed regarding the installation of CCTV cameras. Possible Moderate Low Step 4: Bus Spot will provide appropriate training to individuals that have access to the information generated by the CCTV system. In addition, it will ensure that the employees of the data processor are trained as well. In each entrance of the bus, a sign for the use of CCTV will be displayed. The sign will be visible and readable by all passengers. It will show other details such as the purpose of its use, the identity of Bus Spot, and its contact number in case there are any queries.
Only two employees of Bus Spot will be authorized to access the CCTV system. They will continuously monitor it and report any unusual behavior of bus drivers or passengers to Bus Spot. The requests of individuals that are subject to a criminal activity for accessing the CCTV images will be evaluated only for a limited period of time. If the access is allowed, the CCTV images will be exported by the CCTV system to an appropriate file format. Bus Spot will use a file encryption software to encrypt data before transferring onto another file format. Step 5: Bus Spot's top management has evaluated the DPIA results for the processing of data through CCTV system. The actions suggested to address the identified risks have been approved and will be implemented based on best practices. This DPIA involves the analysis of the risks and impacts in only a group of buses located in the capital of Spain. Therefore, the DPIA will be reconducted for each of Bus Spot's buses in Spain before installing the CCTV system. Based on this scenario, answer the following question:
Question:
Which step of theDPIA methodologydid Bus Spotmisswhen conducting the DPIA?
Answer: A
Explanation:
UnderArticle 35(7)(b) of GDPR, a DPIA must include an assessment of thenecessity and proportionality of processing. This ensures that data processingis lawful, limited, and justified. Bus Spotmissed this step, which is essential for verifyingthe lawful basis for processing CCTV data.
* Option A is correctbecause thenecessity and proportionality assessment was required but not completed.
* Option B is incorrectbecause Bus Spotdocumented data processing activities in the DPIA.
* Option C is incorrectbecausenot aligning with GDPR guidelines does not automatically invalidate a DPIA.
* Option D is incorrectbecauseprior approval from a supervisory authority is only required if high- risk processing is detected without sufficient mitigation measures(Article 36).
References:
* GDPR Article 35(7)(b)(Necessity and proportionality in DPIAs)
* Recital 90(Assessing necessity in a DPIA)
NEW QUESTION # 79
Scenario 7: EduCCS is an online education platform based in Netherlands. EduCCS helps organizations find, manage, and deliver their corporate training. Most of EduCCS's clients are EU residents. EduCCS is one of the few education organizations that have achieved GDPR compliance since 2019. Their DPO is a full-time employee who has been engaged in most data protection processes within the organization. In addition to facilitating GDPR compliance, the DPO acts as an intermediary point between EduCCS and other relevant interested parties. EduCCS's users can benefit from the variety of up-to-date training library and the possibility of accessing it through their phones, tablets, or computers. EduCCS's services are offered through two main platforms: online learning and digital training. To use one of these platforms, users should sign on EduCCS's website by providing their personal information. Online learning is a platform in which employees of other organizations can search for and request the training they need. Through its digital training platform, on the other hand, EduCCS manages the entire training and education program for other organizations.
Organizations that need this type of service need to provide information about their core activities and areas where training sessions are needed. This information is then analyzed by EduCCS and a customized training program is provided. In the beginning, all IT-related serviceswere managed by two employees of EduCCS.
However, after acquiring a large number of clients, managing these services became challenging That is why EduCCS decided to outsource the IT service function to X-Tech. X-Tech provides IT support and is responsible for ensuring the security of EduCCS's network and systems. In addition, X-Tech stores and archives EduCCS's information including their training programs and clients' and employees' data. Recently, X-Tech made headlines in the technology press for being a victim of a phishing attack. A group of three attackers hacked X-Tech's systems via a phishing campaign which targeted the employees of the Marketing Department. By compromising X-Tech's mail server, hackers were able to gain access to more than 200 computer systems. Consequently, access to the networks of EduCCS's clients was also allowed. Using EduCCS's employee accounts, attackers installed a remote access tool on EduCCS's compromised systems.
By doing so, they gained access to personal information of EduCCS's clients, training programs, and other information stored in its online payment system. The attack was detected by X-Tech's system administrator.
After detecting unusual activity in X-Tech's network, they immediately reported it to the incident management team of the company. One week after being notified about the personal data breach, EduCCS communicated the incident to the supervisory authority with a document that outlined the reasons for the delay revealing that due to the lack of regular testing or modification, their incident response plan was not adequately prepared to handle such an attack.Based on this scenario, answer the following question:
Question:
What is therole of EduCCS' DPOin the situation described inscenario 7?
Answer: A
Explanation:
UnderArticle 39(1)(b) of GDPR, the DPO is responsible formonitoring compliance, includingensuring corrective actions are takento prevent future breaches.
* Option A is correctbecauseDPOs must assess whether corrective actions were taken.
* Option B is incorrectbecausethe DPO does not execute the breach response plan but advises on compliance.
* Option C is incorrectbecausedocumenting and reporting breaches is the responsibility of the controller, not solely the DPO.
* Option D is incorrectbecauseDPOs do not handle compensations-this is a legal issue determined by courts.
References:
* GDPR Article 39(1)(b)(DPO's role in monitoring compliance)
* Recital 97(DPO's advisory responsibilities)
NEW QUESTION # 80
Scenario:2
Soyled is a retail company that sells a wide range of electronic products from top European brands. It primarily sells its products in its online platforms (which include customer reviews and ratings), despite using physical stores since 2015. Soyled's website and mobile app are used by millions of customers. Soyled has employed various solutions to create a customer-focused ecosystem and facilitate growth. Soyled uses customer relationship management (CRM) software to analyze user data and administer the interaction with customers. The software allows the company to store customer information, identify sales opportunities, and manage marketing campaigns. It automatically obtains information about each user's IP address and web browser cookies. Soyled also uses the software to collect behavioral data, such as users' repeated actions and mouse movement information. Customers must create an account to buy from Soyled's online platforms. To do so, they fill out a standard sign-up form of three mandatory boxes (name, surname, email address) and a non-mandatory one (phone number). When the user clicks the email address box, a pop-up message appears as follows: "Soyled needs your email address to grant you access to your account and contact you about any changes related to your account and our website. For further information, please read our privacy policy.' When the user clicks the phone number box, the following message appears: "Soyled may use your phone number to provide text updates on the order status. The phone number may also be used by the shipping courier." Once the personal data is provided, customers create a username and password, which are used to access Soyled's website or app. When customers want to make a purchase, they are also required to provide their bank account details. When the user finally creates the account, the following message appears: "Soyled collects only the personal data it needs for the following purposes: processing orders, managing accounts, and personalizing customers' experience. The collected data is shared with our network and used for marketing purposes." Soyled uses personal data to promote sales and its brand. If a user decides to close the account, the personal data is still used for marketing purposes only. Last month, the company received an email from John, a customer, claiming that his personal data was being used for purposes other than those specified by the company. According to the email, Soyled was using the data for direct marketing purposes. John requested details on how his personal data was collected, stored, and processed. Based on this scenario, answer the following question:
Question:
When completing the sign-up form, the user gets a notification about the purpose for which Soyled collects their email address. Is Soyled required by the GDPR to do so?
Answer: A
Explanation:
UnderArticle 13 of GDPR, controllers must inform data subjectsat the time of data collectionabout the purpose of processingtheir personal data. This ensures transparency and accountability.
Soyled provides apop-up messageexplaining why the email is collected, which aligns withGDPR's transparency principles.Option A is correct.Option Bis incorrect because GDPR requires notification at collection, not upon request.Option Cis incorrect as GDPR mandates disclosure of purpose, not just storage and processing methods.Option Dis misleading because the purpose must be disclosedregardless of communication intent.
References:
* GDPR Article 13(1)(c)(Obligation to inform data subjects about processing purposes)
* Recital 60(Transparency and accountability in data collection)
NEW QUESTION # 81
Scenario:
Socianis a softwareused to collect medical records of patients, includingname, date of birth, social security number, and other personal data. The system stores data on asecure server with multi-layered security.
An organization usingSocianfor six months wants to ensure that itsprocessing activities comply with GDPR
. TheDPO advised creating a list of processing activitiesrelated toSocian.
Question:
What should beincludedin theprocessing activities registers?
Answer: A
Explanation:
UnderArticle 30 of GDPR, organizations must documentsecurity measuresused to protect personal data, includingpseudonymization, encryption, and access controls.
* Option C is correctbecausedocumenting protection techniques is required in the processing activity register.
* Option A is incorrectbecauserisk severity assessments are part of DPIAs, not processing registers.
* Option B is incorrectbecausebreach notification procedures are handled separately under Article
33.
* Option D is incorrectbecausewhile access logs are important, they are not required in the processing activity register.
References:
* GDPR Article 30(1)(g)(Security measures must be documented)
* Recital 82(Accountability requires detailed processing records)
NEW QUESTION # 82
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