Q: 13
SCENARIO
Please use the following to answer the next question:
Anna and Frank both work at Granchester University. Anna is a lawyer responsible for data
protection, while Frank is a lecturer in the engineering department. The University maintains a
number of types of records:
Student records, including names, student numbers, home addresses, pre-university information,
university 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 Granchester’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 University encrypts all of its personal data records in transit and at
rest.
In order to improve his teaching, Frank wants to investigate how his engineering students perform in
relational to Department for Education expectations. He has attended one of Anna’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 university attended. He wants to keep the records
at the individual student level. Mindful of Anna’s training, Frank 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 Anna’s tasks is to complete the record of processing activities, as required by the GDPR. After
receiving her email reminder, as required by the GDPR. After receiving her email reminder, Frank
informs Anna about his performance database.
Ann explains to Frank that, as well as minimizing personal data, the University 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. Anna arranges to discuss this further with
Frank after she has done some additional research.
Frank 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 Frank takes the laptop into the University he loses it
on the train. Frank has to see Anna that day to discuss compatible processing. He knows that he
needs to report security incidents, so he decides to tell Anna about his lost laptop at the same time.
Before Anna determines whether Frank’s performance database is permissible, what additional
information does she need?
Options
Discussion
I’d say D here. What students have been told and how the research will be used ties directly to transparency and lawful basis under GDPR. Without that info, you can't assess if they're compliant. Pretty sure that's what matters most for permissibility.
Its C, right? I thought the masking algorithm would be most important here. Not sure, can someone confirm?
C or D here, but D fits GDPR better. The question traps you with C (algorithm details), but for permissibility Anna really needs to know what info students got and how the data will be used. Pretty sure that's the key part for lawfulness. Disagree?
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