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PECB Certified Data Protection Officer Sample Questions (Q71-Q76):
NEW QUESTION # 71
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 question:
Scenario:
Soyled's customers are required to provide theirbank account detailsto buy a product. According to the GDPR, is this data processing lawful?
- A. No, sensitive data, such as bank account details, should only be processed by official authorities.
- B. Yes, because the processing is necessary for the fulfillment of the purchase agreement.
- C. No, because financial information cannot be collected without explicit consent.
- D. Yes, because Soyled has a privacy policy in place that ensures the protection of personal data.
Answer: B
Explanation:
UnderArticle 6(1)(b) of GDPR, processing is lawfulif 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 isnecessaryfor fulfilling the agreement.
* Option A is correctbecause payment data is essential for transaction processing, which aligns with GDPR's contract basis.
* Option B is incorrectbecause having a privacy policy does not automatically justify data processing.
* Option C is incorrectbecause financial data can be processed byauthorized commercial entitiesunder GDPR.
* Option D is incorrectbecauseexplicit consent is not requiredwhen processing is contractually necessary.
References:
* GDPR Article 6(1)(b)(Processing necessary for contract performance)
* Recital 44(Necessity of processing for contract fulfillment)
NEW QUESTION # 72
Scenario1:
MED is a healthcare provider located in Norway. It provides high-quality and affordable healthcare services, including disease prevention, diagnosis, and treatment. Founded in 1995, MED is one of the largest health organizations in the private sector. The company has constantly evolved in response to patients' needs.
Patients that schedule an appointment in MED's medical centers initially need to provide their personal information, including name, surname, address, phone number, and date of birth. Further checkups or admission require additional information, including previous medical history and genetic data. When providing their personal data, patients are informed that the data is used for personalizing treatments and improving communication with MED's doctors. Medical data of patients, including children, are stored in the database of MED's health information system. MED allows patients who are at least 16 years old to use the system and provide their personal information independently. For children below the age of 16, MED requires consent from the holder of parental responsibility before processing their data.
MED uses a cloud-based application that allows patients and doctors to upload and access information.
Patients can save all personal medical data, including test results, doctor visits, diagnosis history, and medicine prescriptions, as well as review and track them at any time. Doctors, on the other hand, can access their patients' data through the application and can add information as needed.
Patients who decide to continue their treatment at another health institution can request MED to transfer their data. However, even if patients decide to continue their treatment elsewhere, their personal data is still used by MED. Patients' requests to stop data processing are rejected. This decision was made by MED's top management to retain the information of everyone registered in their databases.
The company also shares medical data with InsHealth, a health insurance company. MED's data helps InsHealth create health insurance plans that meet the needs of individuals and families.
MED believes that it is its responsibility to ensure the security and accuracy of patients' personal data. Based on the identified risks associated with data processing activities, MED has implemented appropriate security measures to ensure that data is securely stored and processed.
Since personal data of patients is stored and transmitted over the internet, MED uses encryption to avoid unauthorized processing, accidental loss, or destruction of data. The company has established a security policy to define the levels of protection required for each type of information andprocessing activity. MED has communicated the policy and other procedures to personnel and provided customized training to ensure proper handling of data processing.
Question:
Based on scenario 1, is the processing of children's personal data performed by MED in compliance with GDPR?
- A. Yes, the processing of children's personal data below the age of 16 years with parental consent is in compliance with GDPR.
- B. No, the processing of personal data of children below the age of 16 years is not in compliance with the GDPR, even if parental consent is provided.
- C. Yes, as long as the processing is conducted with industry-standard encryption.
- D. No, MED must obtain explicit consent from the child, regardless of parental consent, for the processing to be in compliance with GDPR.
Answer: A
Explanation:
UnderArticle 8 of the GDPR, the processing of personal data of children under 16 years is only lawful if parental or guardian consent is obtained. However, Member States can lower the age limit to 13 years if they choose.
In this scenario, MED requires parental consent for children below 16 years, which aligns with GDPR requirements. Therefore,Option Bis correct.Option Ais incorrect because GDPR allows parental consent.
Option Cis incorrect because GDPR does not require explicit consent from the child when parental consent is given.Option Dis incorrect because encryption alone does not determine compliance.
References:
* GDPR Article 8(Conditions for children's consent)
* Recital 38(Protection of children's data)
NEW QUESTION # 73
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 question:
According to scenario 8, by storing clients' information in separate databases, MA store used a:
- A. Pseudonymization method
- B. Data protection by design strategy
- C. Data protection by default technology
Answer: B
Explanation:
Separating databases for different types of data aligns with the principle ofData Protection by Design and by Defaultunder Article 25 of GDPR. By structuring data storage in a way that limits access and minimizes exposure, MA Store is proactively implementing security measures that prevent unauthorized access and mitigate risks in case of a breach. This approach supports theconfidentiality, integrity, and availabilityof personal data as required by GDPR.
NEW QUESTION # 74
Scenario:
Aclinical research organizationcollects and processessensitive personal dataof individuals formedical research purposes. The data isencrypted and stored in a central database using a one-way hashing function (bcrypt). The organization conducted arisk assessmentto identify andmitigate risks.
Question:
Should aDPIA be conductedin this case?
- A. No, because the personal datais encrypted.
- B. Yes, a DPIA should be conducted whensensitive personal data of vulnerable personsis collected, based on theidentified risk from the risk assessment.
- C. No, because the organizationhas already conducted a risk assessment.
- D. Yes, but only if the data isretained for more than five years.
Answer: B
Explanation:
UnderArticle 35(3)(b) of GDPR, aDPIA is required for large-scale processing of sensitive data, including medical research on vulnerable individuals.
* Option A is correctbecausemedical data and research involving vulnerable individuals require a DPIA.
* Option B is incorrectbecauseencryption does not eliminate the need for a DPIA if the processing poses high risks.
* Option C is incorrectbecausea general risk assessment does not replace a DPIAunderArticle 35.
* Option D is incorrectbecauseretention period is not a deciding factor for DPIA necessity.
References:
* GDPR Article 35(3)(b)(DPIA for special category data)
* Recital 91(Risks to fundamental rights require DPIAs)
NEW QUESTION # 75
Which of the statements below related to compliance monitoring is correct?
- A. The DPO should assign roles and responsibilities to monitor GDPR compliance
- B. The DPO should monitor internal compliance of the organization with applicable data protection laws
- C. The DPO should monitor and measure all activities of the organization in order to ensure the suitability and effectiveness of the GDPR compliance program
Answer: B
Explanation:
GDPR Article 39(1)(b) states that the DPO is responsible for monitoring internal compliance with data protection laws, rather than assigning responsibilities or measuring all activities.
NEW QUESTION # 76
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