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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 transported daily. 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 DPI
Under Article 35(11) of GDPR, controllers must reassess DPIAs regularly to account for changing risks in processing activities like CCTV surveillance.
Option D is correct because CCTV monitoring poses an ongoing risk, requiring periodic DPIA reviews.
Option A is incorrect because regular DPIA reviews are required, even if the data processing remains the same.
Option B is incorrect because transparency is a key principle of GDPR, and displaying information does not breach GDPR.
Option C is incorrect because data processors can process CCTV data as long as there is a processing agreement (Article 28).
GDPR Article 35(11) (Periodic DPIA review)
Recital 90 (Regular assessment of risks)
Scenario 5:
Recpond is a German employment recruiting company. Their services are delivered globally and include consulting and staffing solutions. In the beginning. Recpond provided its services through an office in Germany. Today, they have grown to become one of the largest recruiting agencies, providing employment to more than 500,000 people around the world. Recpond receives most applications through its website. Job searchers are required to provide the job title and location. Then, a list of job opportunities is provided. When a job position is selected, candidates are required to provide their contact details and professional work experience records. During the process, they are informed that the information will be used only for the purposes and period determined by Recpond. Recpond's experts analyze candidates' profiles and applications and choose the candidates that are suitable for the job position. The list of the selected candidates is then delivered to Recpond's clients, who proceed with the recruitment process. Files of candidates that are not selected are stored in Recpond's databases, including the personal data of candidates who withdraw the consent on which the processing was based. When the GDPR came into force, the company was unprepared. The top management appointed a DPO and consulted him for all data protection issues. The DPO, on the other hand, reported the progress of all data protection activities to the top management. Considering the level of sensitivity of the personal data processed by Recpond, the DPO did not have direct access to the personal data of all clients, unless the top management deemed it necessary. The DPO planned the GDPR implementation by initially analyzing the applicable GDPR requirements. Recpond, on the other hand, initiated a risk assessment to understand the risks associated with processing operations. The risk assessment was conducted based on common risks that employment recruiting companies face. After analyzing different risk scenarios, the level of risk was determined and evaluated. The results were presented to the DPO, who then decided to analyze only the risks that have a greater impact on the company. The DPO concluded that the cost required for treating most of the identified risks was higher than simply accepting them. Based on this analysis, the DPO decided to accept the actual level of the identified risks. After reviewing policies and procedures of the company. Recpond established a new data protection policy. As proposed by the DPO, the information security policy was also updated. These changes were then communicated to all employees of Recpond. Based on this scenario, answer the following Questio n:
Questio n:
Based on scenario 5, the DPO reports directly to Recpond's top management. Is this in alignment with GDPR requirements?
Under Article 38(3) of GDPR, the DPO must report directly to the highest level of management to ensure independence and avoid interference in their tasks.
Option A is correct because GDPR requires direct reporting to top management.
Option B is incorrect because the DPO does not report to the supervisory authority, but they can liaise with it.
Option C is incorrect because GDPR does not allow reporting to middle management.
Option D is incorrect because department heads cannot oversee the DPO's work, ensuring they remain free from conflict of interest.
GDPR Article 38(3) (DPO must report to highest management)
Recital 97 (DPO's independence and protection from undue influence)
Scenario 3:
COR Bank is an international banking group that operates in 31 countries. It was formed as the merger of two well-known investment banks in Germany. Their two main fields of business are retail and investment banking. COR Bank provides innovative solutions for services such as payments, cash management, savings, protection insurance, and real-estate services. COR Bank has a large number of clients and transactions. Therefore, they process large information, including clients' personal dat
a. Some of the data from the application processes of COR Bank, including archived data, is operated by Tibko, an IT services company located in Canada. To ensure compliance with the GDPR, COR Bank and Tibko have reached a data processing agreement Based on the agreement, the purpose and conditions of data processing are determined by COR Bank. However, Tibko is allowed to make technical decisions for storing the data based on its own expertise. COR Bank aims to remain a trustworthy bank and a long-term partner for its clients. Therefore, they devote special attention to legal compliance. They started the implementation process of a GDPR compliance program in 2018. The first step was to analyze the existing resources and procedures. Lisa was appointed as the data protection officer (DPO). Being the information security manager of COR Bank for many years, Lisa had knowledge of the organization's core activities. She was previously involved in most of the processes related to information systems management and data protection. Lisa played a key role in achieving compliance to the GDPR by advising the company regarding data protection obligations and creating a data protection strategy. After obtaining evidence of the existing data protection policy, Lisa proposed to adapt the policy to specific requirements of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of departments. As the DPO, she had access to several departments, including HR and Accounting Department. This assured the organization that there was a continuous cooperation between them. The activities of some departments within COR Bank are closely related to data protection. Therefore, considering their expertise, Lisa was advised from the top management to take orders from the heads of those departments when taking decisions related to their field. Based on this scenario, answer the following Questio n:
Questio n:
According to scenario 3, Lisa was appointed as the Data Protection Officer (DPO) of COR Bank. Is this action in compliance with GDPR?
Under Article 37(6) of GDPR, the DPO can be an employee of the company or an external contractor. Lisa's appointment complies with GDPR because she is a staff member with data protection expertise.
Option A is correct because GDPR allows organizations to appoint an internal or external DPO.
Option B is incorrect because a DPO does not have to be an internal staff member even for special categories of data.
Option C is incorrect because a company can appoint an internal DPO even if it operates internationally.
Option D is incorrect because having another role does not disqualify someone from being a DPO, as long as there is no conflict of interest.
GDPR Article 37(6) (DPO may be an employee or external contractor)
Recital 97 (DPO qualifications and independence)
Scenario 8: MA store is an online clothing retailer founded in 2010. They provide quality products at a reasonable cost. One thing that differentiates MA store from other online shopping sites is their excellent customer service.
MA store follows a customer-centered business approach. They have created a user-friendly website with well-organized content that is accessible to everyone. Through innovative ideas and services, MA store offers a seamless user experience for visitors while also attracting new customers. When visiting the website, customers can filter their search results by price, size, customer reviews, and other features. One of MA store's strategies for providing, personalizing, and improving its products is data analytics. MA store tracks and analyzes the user actions on its website so it can create customized experience for visitors.
In order to understand their target audience, MA store analyzes shopping preferences of its customers based on their purchase history. The purchase history includes the product that was bought, shipping updates, and payment details. Clients' personal data and other information related to MA store products included in the purchase history are stored in separate databases. Personal information, such as clients' address or payment details, are encrypted using a public key. When analyzing the shopping preferences of customers, employees access only the information about the product while the identity of customers is removed from the data set and replaced with a common value, ensuring that customer identities are protected and cannot be retrieved.
Last year, MA store announced that they suffered a personal data breach where personal data of clients were leaked. The personal data breach was caused by an SQL injection attack which targeted MA store's web application. The SQL injection was successful since no parameterized queries were used.
Based on this scenario, answer the following Questio n:
According to scenario 8, MA store analyzed shopping preferences of its customers by analyzing the product they have bought in the customer's purchase history. Which option is correct in this case?
Since the data is pseudonymized (not fully anonymized), it remains personal data under GDPR and cannot be retained indefinitely. Article 5(1)(e) of GDPR states that personal data must be kept only for as long as necessary for the intended processing purpose. Additionally, Recital 26 of GDPR clarifies that pseudonymized data is still considered personal data if re-identification is possible. Therefore, MA Store must implement a retention policy that ensures the data is deleted or further anonymized once it is no longer needed for analysis.
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 Questio n:
Scenario:
Soyled's customers are required to provide their bank account details to buy a product. According to the GDPR, is this data processing lawful?
Under Article 6(1)(b) of GDPR, processing is lawful if it is necessary for the performance of a contract with the data subject. Since the customers must provide bank details to complete their purchases, this processing is necessary for fulfilling the agreement.
Option A is correct because payment data is essential for transaction processing, which aligns with GDPR's contract basis.
Option B is incorrect because having a privacy policy does not automatically justify data processing.
Option C is incorrect because financial data can be processed by authorized commercial entities under GDPR.
Option D is incorrect because explicit consent is not required when processing is contractually necessary.
GDPR Article 6(1)(b) (Processing necessary for contract performance)
Recital 44 (Necessity of processing for contract fulfillment)
