Question # 1 Which of the following is the weakest lawful basis for processing employee personal data?
A. Processing based on fulfilling an employment contract.
B. Processing based on employee consent.
C. Processing based on legitimate interests.
D. Processing based on legal obligation
Click for Answer
B. Processing based on employee consent.
Answer Description Reference: https://www.itgovernance.co.uk/blog/gdpr-lawful-bases-for-processing-withexamples
Question # 2 Under Article 30 of the GDPR, controllers are required to keep records of all of the following EXCEPT?
A. Incidents of personal data breaches, whether disclosed or not.
B. Data inventory or data mapping exercises that have been conducted.
C. Categories of recipients to whom the personal data have been disclosed.
D. Retention periods for erasure and deletion of categories of personal data.
Click for Answer
D. Retention periods for erasure and deletion of categories of personal data.
Answer Description Explanation: Section: (none) Explanation Reference: https://medium.com/golden-data/what-records-must-controllers-andprocessors- keep-to-comply- with-eu-data-protection-law-3e8bac177695
Question # 3 According to Article 84 of the GDPR, the rules on penalties applicable to infringements shall be laid down by?
A. The local Data Protection Supervisory Authorities.
B. The European Data Protection Board.
C. The EU Commission.
D. The Member States.
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Question # 4 Please use the following to answer the next question: Due to rapidly expanding workforce, Company A has decided to outsource its payroll function to Company B. Company B is an established payroll service provider with a sizable client base and a solid reputation in the industry. Company B’s payroll solution for Company A relies on the collection of time and attendance data obtained via a biometric entry system installed in each of Company A’s factories. Company B won’t hold any biometric data itself, but the related data will be uploaded to Company B’s UK servers and used to provide the payroll service. Company B’s live systems will contain the following information for each of Company A’s employees: Name Address Date of Birth Payroll number National Insurance number Sick pay entitlement Maternity/paternity pay entitlement Holiday entitlement Pension and benefits contributions Trade union contributions Jenny is the compliance officer at Company A. She first considers whether Company A needs to carry out a data protection impact assessment in relation to the new time and attendance system, but isn’t sure whether or not this is required. Jenny does know, however, that under the GDPR there must be a formal written agreement requiring Company B to use the time and attendance data only for the purpose of providing the payroll service, and to apply appropriate technical and organizational security measures for safeguarding the data. Jenny suggests that Company B obtain advice from its data protection officer. The company doesn’t have a DPO but agrees, in the interest of finalizing the contract, to sign up for the provisions in full. Company A enters into the contract. Weeks later, while still under contract with Company A, Company B embarks upon a separate project meant to enhance the functionality of its payroll service, and engages Company C to help. Company C agrees to extract all personal data from Company B’s live systems in order to create a new database for Company B. This database will be stored in a test environment hosted on Company C’s U.S. server. The two companies agree not to include any data processing provisions in their services agreement, as data is only being used for IT testing purposes. Unfortunately, Company C’s U.S. server is only protected by an outdated IT security system, and suffers a cyber security incident soon after Company C begins work on the project. As a result, data relating to Company A’s employees is visible to anyone visiting Company C’s website. Company A is unaware of this until Jenny receives a letter from the supervisory authority in connection with the investigation that ensues. As soon as Jenny is made aware of the breach, she notifies all affected employees. Under the GDPR, which of Company B’s actions would NOT be likely to trigger a potential enforcement action?
A. Their omission of data protection provisions in their contract with Company C.
B. Their failure to provide sufficient security safeguards to Company A’s data.
C. Their engagement of Company C to improve their payroll service.
D. Their decision to operate without a data protection officer.
Click for Answer
C. Their engagement of Company C to improve their payroll service.
Question # 5 Which judicial body makes decisions on actions taken by individuals wishing to enforce their rights under EU law?
A. Court of Auditors
B. Court of Justice of European Union
C. European Court of Human Rights
D. European Data Protection Board
Click for Answer
B. Court of Justice of European Union
Question # 6 Please use the following to answer the next question: ABC Hotel Chain and XYZ Travel Agency are U.S.-based multinational companies. They use an internet-based common platform for collecting and sharing their customer data with each other, in order to integrate their marketing efforts. Additionally, they agree on the data to be stored, how reservations will be booked and confirmed, and who has access to the stored data. Mike, an EU resident, has booked travel itineraries in the past through XYZ Travel Agency to stay at ABC Hotel Chain’s locations. XYZ Travel Agency offers a rewards program that allows customers to sign up to accumulate points that can later be redeemed for free travel. Mike has signed the agreement to be a rewards program member. Now Mike wants to know what personal information the company holds about him. He sends an email requesting access to his data, in order to exercise what he believes are his data subject rights. What are ABC Hotel Chain and XYZ Travel Agency’s roles in this relationship?
A. ABC Hotel Chain is the controller and XYZ Travel Agency is the processor.
B. XYZ Travel Agency is the controller and ABC Hotel Chain is the processor.
C. ABC Hotel Chain and XYZ Travel Agency are independent controllers.
D. ABC Hotel Chain and XYZ Travel Agency are joint controllers.
Click for Answer
A. ABC Hotel Chain is the controller and XYZ Travel Agency is the processor.
Question # 7 An online company’s privacy practices vary due to the fact that it offers a wide variety of services. How could it best address the concern that explaining them all would make the policies incomprehensible?
A. Use a layered privacy notice on its website and in its email communications.
B. Identify uses of data in a privacy notice mailed to the data subject.
C. Provide only general information about its processing activities and offer a toll-free number for more information.
D. Place a banner on its website stipulating that visitors agree to its privacy policy and terms of use by visiting the site.
Click for Answer
B. Identify uses of data in a privacy notice mailed to the data subject.
Answer Description Reference: https://www.ftc.gov/sites/default/files/documents/reports/federal-tradecommission- bureau- consumer-protection-preliminary-ftc-staff-report-protectingconsumer/ 101201privacyreport.pdf
Question # 8 Under the Data Protection Law Enforcement Directive of the EU, a government can carry out covert investigations involving personal data, as long it is set forth by law and constitutes a measure that is both necessary and what?
A. Prudent.
B. Important.
C. Proportionate.
D. DPA-approved.
Click for Answer
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