Q: 15
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' dat
a. 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 Questio
n:
Questio n:
What is the role of EduCCS' DPO in the situation described in scenario 7?
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