Under the General Data Protection Regulation (GDPR), what must be included in a written agreement between the controller and processor in relation to processing conducted on the controller's behalf?

SCENARIO

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You were recently hired by InStyte Date Corp as a privacy manager to help InStyle Data Corp become compliant with a new data protection law

The law mandates that businesses have reasonable and appropriate security measures in place to protect personal data. Violations of that mandate are heavily fined and the legislators have stated that they will aggressively pursue companies that don t comply with the new law

You are paved with a security manager and tasked with reviewing InStyle Data Corp s current state and advising the business how it can meet the "reasonable and appropriate security" requirement InStyle Data Corp has grown rapidly and has not kept a data inventory or completed a data mapping InStyte Data Corp has also developed security-related policies ad hoc and many have never been implemented The various teams involved in the creation and testing of InStyle Data Corp s products experience significant turnover and do not have well defined roles There's little documentation addressing what personal data is processed by which product and for what purpose

Work needs to begin on this project immediately so that InStyle Data Corp can become compliant by the time the law goes into effect. You and you partner discover that InStyle Data Corp regularly sends files containing sensitive personal data back to its customers through email sometimes using InStyle Data Corp employees personal email accounts. You also team that InStyle Data Corp s privacy and information security teams are not informed of new personal data flows, new products developed by InStyte Data Corp that process personal data, or updates to existing InStyle Data Corp products that may change what or how the personal data is processed until after the product or update has gone have.

Through a review of InStyle Date Corp’s test and development environment logs, you discover InStyle Data Corp sometimes gives login credentials to any InStyle Data Corp employee or contractor who requests them. The test environment only contains dummy data but the development environment contains personal data including Social Security Numbers, hearth ^formation and financial information All credentialed InStyle Data Corp employees and contractors have the ability to after and delete personal data in both environments regardless of their role or what project they are working on.

You and your partner provide a gap assessment citing the issues you spotted, along with recommended remedial actions and a method to measure implementation InStyle Data Corp implements all of the recommended security controls You review the processes roles, controls and measures taken to appropriately protect the personal data at every stop However, you realize there is no plan for monitoring and nothing in place addressing sanctions for violations of the updated policies and procedures InStyle Data Corp pushes back, stating they do not have the resources for such monitoring.

What aspect of the data management life cycle will still be unaddressed it you cannot find the resources to become compliant?

SCENARIO

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As they company’s new chief executive officer, Thomas Goddard wants to be known as a leader in data protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically Questionable practices, including unauthorized sales of personal data to marketers. Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company’s claims that “appropriate” data protection safeguards were in place. The scandal affected the company’s business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard’s mentor, was forced to step down.

Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company’s board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures. He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. “We want Medialite to have absolutely the highest standards,” he says. “In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company’s finances. So, while I want the best solutions across the board, they also need to be cost effective.”

You are told to report back in a week’s time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.

The CEO likes what he’s seen of the company’s improved privacy program, but wants additional assurance that it is fully compliant with industry standards and reflects emerging best practices. What would best help accomplish this goal?

What have experts identified as an important trend in privacy program development?

A marketing team regularly exports spreadsheets to use (or analysis including customer name, birthdate and home address. These spreadsheets are routinely shared between members of various teams via email even with employees that do not need such granular data.

What is the best way to lower overall risk?

SCENARIO

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Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can be used in the home to manage family calendars, do online shopping, and schedule doctor appointments. After having had a successful launch in the United States, the Handy Helper is about to be made available for purchase worldwide.

The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the whole family, including children, but does not provide any further detail or privacy notice. In order to use the application, a family creates a single account, and the primary user has access to all information about the other users. Upon start up, the primary user must check a box consenting to receive marketing emails from Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.

Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European distributor of Handy Helper when he fielded many Questions about the product from the distributor. Sanjay needed to look more closely at the product in order to be able to answer the Questions as he was not involved in the product development process.

In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the

product. This data is all stored in the cloud and is encrypted both during transmission and at rest.

Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent Omnimedia employees have access to user data under a program called Eureka. Omnipresent Omnimedia is hoping that at some point in the future, the data will reveal insights that could be used to create a fully automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is considered a long-term goal.

What can Sanjay do to minimize the risks of offering the product in Europe?

SCENARIO

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Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new privacy officer. The company is based in California but thanks to some great publicity from a social media influencer last year, the company has received an influx of sales from the EU and has set up a regional office in Ireland to support this expansion. To become familiar with Ace Space’s practices and assess what her privacy priorities will be, Penny has set up meetings with a number of colleagues to hear about the work that they have been doing and their compliance efforts.

Penny’s colleague in Marketing is excited by the new sales and the company’s plans, but is also concerned that Penny may curtail some of the growth opportunities he has planned. He tells her “I heard someone in the breakroom talking about some new privacy laws but I really don’t think it affects us. We’re just a small company. I mean we just sell accessories online, so what’s the real risk?” He has also told her that he works with a number of small companies that help him get projects completed in a hurry. “We’ve got to meet our deadlines otherwise we lose money. I just sign the contracts and get Jim in finance to push through the payment. Reviewing the contracts takes time that we just don’t have.”

In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken a number of precautions to protect its website from malicious activity, it has not taken the same level of care of its physical files or internal infrastructure. Penny’s colleague in IT has told her that a former employee lost an encrypted USB key with financial data on it when he left. The company nearly lost access to their customer database last year after they fell victim to a phishing attack. Penny is told by her IT colleague that the IT team “didn’t know what to do or who should do what. We hadn’t been trained on it but we’re a small team though, so it worked out OK in the end.” Penny is concerned that these issues will compromise Ace Space’s privacy and data protection.

Penny is aware that the company has solid plans to grow its international sales and will be working closely with the CEO to give the organization a data “shake up”. Her mission is to cultivate a strong privacy culture within the company.

Penny has a meeting with Ace Space’s CEO today and has been asked to give her first impressions and an overview of her next steps.

What information will be LEAST crucial from a privacy perspective in Penny’s review of vendor contracts?

For an organization that has just experienced a data breach, what might be the least relevant metric for a company's privacy and governance team?

If your organization has a recurring issue with colleagues not reporting personal data breaches, all of the following are advisable to do EXCEPT?

With whom would it be best for a privacy professional in an organization to consult regarding Privacy-Enhancing Technologies (PETs)?