Q: 11
Questio n:
What is the role of the European Data Protection Board (EDPB)?
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Q: 12
Scenario:
ChatBubble is a software company that stores personal data, including usernames, emails, and
passwords. Last month, an attacker gained access to ChatBubble’s system, but the personal data was
encrypted, preventing unauthorized access.
Questio n:
Should the data subjects be notified in this case?
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Q: 13
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:
According to scenario 5, what should Recpond have considered when assessing the risks related to
processing operations?
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Q: 14
Scenario:
Pinky, a retail company, received a request from a data subject to identify which purchases they had
made at different physical store locations. However, Pinky does not link purchase records to
customer identities, since purchases do not require account creation.
Questio n:
Should Pinky process additional information from customers in order to identify the data subject as
requested?
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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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Question 11 of 20 · Page 2 / 2