Scenario 4:

Berc is a pharmaceutical company headquartered in Paris, France, known for developing inexpensive improved healthcare products. They want to expand to developing life-saving treatments. Berc has been engaged in many medical researches and clinical trials over the years. These projects required the processing of large amounts of data, including personal information. Since 2019, Berc has pursued GDPR compliance to regulate data processing activities and ensure data protection. Berc aims to positively impact human health through the use of technology and the power of collaboration. They recently have created an innovative solution in participation with Unty, a pharmaceutical company located in Switzerland. They want to enable patients to identify signs of strokes or other health-related issues themselves. They wanted to create a medical wrist device that continuously monitors patients' heart rate and notifies them about irregular heartbeats. The first step of the project was to collect information from individuals aged between 50 and 65. The purpose and means of processing were determined by both companies. The information collected included age, sex, ethnicity, medical history, and current medical status. Other information included names, dates of birth, and contact details. However, the individuals, who were mostly Berc's and Unty's customers, were not aware that there was an arrangement between Berc and Unty and that both companies have access to their personal data and share it between them. Berc outsourced the marketing of their new product to an international marketing company located in a country that had not adopted the adequacy decision from the EU commission. However, since they offered a good marketing campaign, following the DPO's advice, Berc contracted it. The marketing campaign included advertisement through telephone, emails, and social media. Berc requested that Berc’s and Unty's clients be first informed about the product. They shared the contact details of clients with the marketing company. Based on this scenario, answer the following question:

Question:

Based on scenario 4, Berc shared personal information of its clients with an international marketing company even though an adequacy decision was absent . Which of the following is a valid reason to do so?

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:

Question:

When completing the sign-up form, the user gets a notification about the purpose for which Soyled collects their email address. Is Soyled required by the GDPR to do so?

Which statement below regarding the difference between anonymization and pseudonymization is correct?

Scenario 3 :

COR Bank is an international banking group that operates in 31 countries. It was formed as the merger of two well-known investment banks in Germany. Their two main fields of business are retail and investment banking. COR Bank provides innovative solutions for services such as payments, cash management, savings, protection insurance, and real-estate services. COR Bank has a large number of clients and transactions. Therefore, they process large information, including clients' personal data. Some of the data from the application processes of COR Bank, including archived data, is operated by Tibko, an IT services company located in Canada. To ensure compliance with the GDPR, COR Bank and Tibko have reached a data processing agreement Based on the agreement, the purpose and conditions of data processing are determined by COR Bank. However, Tibko is allowed to make technical decisions for storing the data based on its own expertise. COR Bank aims to remain a trustworthy bank and a long-term partner for its clients. Therefore, they devote special attention to legal compliance. They started the implementation process of a GDPR compliance program in 2018. The first step was to analyze the existing resources and procedures. Lisa was appointed as the data protection officer (DPO). Being the information security manager of COR Bank for many years, Lisa had knowledge of the organization's core activities. She was previously involved in most of the processes related to information systems management and data protection. Lisa played a key role in achieving compliance to the GDPR by advising the company regarding data protection obligations and creating a data protection strategy. After obtaining evidence of the existing data protection policy, Lisa proposed to adapt the policy to specific requirements of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of departments. As the DPO, she had access to several departments, including HR and Accounting Department. This assured the organization that there was a continuous cooperation between them. The activities of some departments within COR Bank are closely related to data protection. Therefore, considering their expertise, Lisa was advised from the top management to take orders from the heads of those departments when taking decisions related to their field. Based on this scenario, answer the following question:

Question:

According to scenario 3, Tibko stores archived data on behalf of COR Bank . This means that Tibko is a:

Question:

According to the principle of data minimization , data must be:

Question:

All the statements below regarding the lawfulness of processing are correct, except :

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:

Question:

The GDPR indicates that the processing of personal data should be based on a legal contract with the data subject. Based on scenario 6, has Soyled fulfilled this requirement?

Scenario:

PickFood is an online food delivery service that allows customers to order food online and pay by credit card . The payment service is provided by PaySmart , which processes the transactions.

Question:

According to Article 30 of GDPR , what type of information should PaySmart NOT maintain when recording online transaction processing activity?

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' data. 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 question:

Question:

Based on scenario 7, due to the attack, personal data of EduCCS' clients (such as names, email addresses, and phone numbers) were unlawfully accessed.

According to GDPR, when must EduCCS inform its clients about this personal data breach?

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:

Which de-identification method has MA store used when analyzing the shopping preferences of its customers?