SCENARIO – Please use the following to answer the next question:Dracarys Inc. is a large multinational company with headquarters in Seattle, Washington, U.S.A. Dracarys began as a small company making and selling women's clothing, but rapidly grew through its early innovative use of online platforms to sell its products. Dracarys is now one of the biggest names in the industry, and employs staff across the globe, and in Asia has employees located in both Singapore and Hong Kong.Due to recent management restructuring they have decided, on the advice of external consultants, to open an office in India in order to centralize its call center as well as its internal human resource functions for the Asia region.Dracarys would like to centralize the following human resource functions in India:

Employee assessment and records management;

Employee benefits administration, including health insurance.Dracarys will have employees on the ground in India managing the systems for the functions listed above. They have been presented with a variety of vendor options for these systems, and are currently assessing the suitability of these vendors for their needs.The CEO of Dracarys is concerned about the behavior of her employees, especially online. After having proprietary company information being shared with competitors by former employees, she is eager to put certain measures in place to ensure that the activities of her employees, while on Dracarys' premises or when using any of Dracarys' computers and networks are not detrimental to the business.Dracarys' external consultants are also advising the company on how to increase earnings. Dracary's management refuses to reduce production costs and compromise the quality of their garments, so the consultants suggested utilizing customer data to create targeted advertising and thus increase sales.Dracarys and their vendor of choice must draft a contract that establishes agreement regarding all of the following factors EXCEPT?

Data subject consent provisions.

In India, the obligation to appoint a Grievance Officer applies ONLY to companies that?

Deal with sensitive personal data.

Conduct cross-border data transfers.

Are considered part of the public sector.

Lack alternate enforcement mechanisms.

In Hong Kong's revised Breach Guidance Note of 2015, what course of action did the Commissioner recommend that companies take immediately after experiencing a breach?

Enlist the aid of law enforcement to determine the cause of the breach.

Proceed under the assumption that the breach is a threat to personal safety.

Enlist the aid of law enforcement to determine the cause of the breach.

Quickly issue a notification to the data subjects affected by the breach.

Immediately gather essential information in relation to the breach.

How can the privacy principles issued in 1980 by the Organisation for Economic Cooperation and Development (OECD) be defined?

Guidelines governing the protection of privacy and trans-border data flows of personal data in states that are members.

Guidelines governing the protection of privacy and trans-border data flows issued in collaboration with the Federal Trade Commission.

Guidelines governing the protection of privacy and trans-border data flows of personal data in states that are members.

Mandatory rules governing the protection of privacy and trans-border data flows within the European Union.

Mandatory rules governing the protection of privacy and trans-border data flows among binding member states.

In 2013-14, the Indian Supreme Court ruled in Puttaswamy and Anr. vs Union of India that requiring a Unique Identification Number was unconstitutional if what?

It was restricted to residents of India.

It was necessary for proving citizenship.

It was required in order to obtain government services.

It was used to gather information to discriminate against minorities.

Which of the following is NOT excluded from the scope of Singapore's Do Not Call registry?

Messages that conduct market research.

Messages that promote investment opportunities.

Messages that conduct market research.

Messages from charitable organizations.

Messages from political candidates.

Section 43A of India's IT Rules 2011 requires which of the following for a privacy policy?

It should be available and produced on request.

It should be published on the website of the body corporate.

It should be emailed or faxed to data providers by the body corporate.

It should be shown to the data provider at the time of data collection.

SCENARIO – Please use the following to answer the next question:Zoe is the new Compliance Manager for the Star Hotel Group, which has five hotels across Hong Kong and China. On her first day, she does an inspection of the largest property, StarOne. She starts with the hotel reception desk. Zoe sees the front desk assistant logging in to a database as he is checking in a guest. The hotel manager, Bernard, tells her that all guest data, including passport numbers, credit card numbers, home address, mobile number and other information associated with a guest's stay is held in a database. Bernard tells her not to worry about the security of the database because it is operated for Star Hotels by a local service provider called HackProof, who therefore are responsible for all the guest data.Zoe notices what looks like a CCTV camera in the corner of the reception area. Bernard says they record all activity in the lobby. In fact, last Tuesday he had received a data access request from a lawyer requesting a copy of footage of all lobby activity for the preceding month. The lawyer's covering letter said that his client has never visited the hotel herself, but is investigating whether her husband has been doing so without her knowledge.Zoe and Bernard head up to the hotel spa. The spa is independently owned by a company called Relax Ltd. Bernard explains that Relax Ltd is a small company and, as they don't have their own database, they transfer data about the spa guests to StarOne staff so that they can upload the data into the HackProof system. Relax Ltd staff can then login and review their guest data as needed.Zoe asks more about the HackProof system. Bernard tells her that the server for the Hong Kong hotels is in Hong Kong, but there is a server in Shenzhen that has a copy of all the Hong Kong hotel data and supports the properties in China. The data is in China for back up purposes and also is accessible by staff in the China hotels so they can better service guests who visit their hotels in both territories.HackProof reports to Zoe that a copy of the entire guest database has been exfiltrated by a hacker.What is Zoe's best course of action?

Zoe should consider if there is a real risk of harm to the guests and take appropriate action based on her assessment.

Zoe must immediately notify all guests, the police and the Privacy Commissioner of the breach.

Zoe does not need to do anything as there is no mandatory breach notification requirement in Hong Kong.

Zoe must report the breach to the Privacy Commissioner and make an action plan together with the Commissioner.

Zoe should consider if there is a real risk of harm to the guests and take appropriate action based on her assessment.

In 2015, Section 66A of India's IT Act was ruled unconstitutional.What did this section previously prohibit?

Publishing images with sexually explicit content.

Tampering with computer source documents.

Publishing private images of others.

In the area of human rights, what separates Singapore from many other Asian countries?

It has not signed the International Covenant on Civil and Political Rights.

It is not a member of the Association of Southeast Asian Nations (ASEAN).

It has not signed the International Covenant on Civil and Political Rights.

It has not adopted the ASEAN Human Rights Declaration.

It is not a member of the United Nations.

SCENARIO – Please use the following to answer the next question:Dracarys Inc. is a large multinational company with headquarters in Seattle, Washington, U.S.A. Dracarys began as a small company making and selling women's clothing, but rapidly grew through its early innovative use of online platforms to sell its products. Dracarys is now one of the biggest names in the industry, and employs staff across the globe, and in Asia has employees located in both Singapore and Hong Kong.Due to recent management restructuring they have decided, on the advice of external consultants, to open an office in India in order to centralize its call center as well as its internal human resource functions for the Asia region.Dracarys would like to centralize the following human resource functions in India:

Employee assessment and records management;

Employee benefits administration, including health insurance.Dracarys will have employees on the ground in India managing the systems for the functions listed above. They have been presented with a variety of vendor options for these systems, and are currently assessing the suitability of these vendors for their needs.The CEO of Dracarys is concerned about the behavior of her employees, especially online. After having proprietary company information being shared with competitors by former employees, she is eager to put certain measures in place to ensure that the activities of her employees, while on Dracarys' premises or when using any of Dracarys' computers and networks are not detrimental to the business.Dracarys' external consultants are also advising the company on how to increase earnings. Dracary's management refuses to reduce production costs and compromise the quality of their garments, so the consultants suggested utilizing customer data to create targeted advertising and thus increase sales.Dracary's existing client data sets have been anonymised but the CEO is concerned about re-identification and the risks of using the data for further analysis.What should the CEO do?

Assess the business risk of further processing in the absence of any regulations on anonymised data.

Refer to India's Information Technology Act and the 2011 rules 3-8 for guidance on handling anonymised data.

Obtain the consent of the data subjects because anonymous data must be treated as personal data at all times.

Adhere to the Singapore guidelines on anonymization and the Hong Kong Guidance on Personal Data Erasure and Anonymization.

SCENARIO – Please use the following to answer the next question:B-Star Limited is a Singapore based construction company with many foreign construction workers. B-Star's HR team maintains two databases. One (the "simple database") contains basic details from a standard in-processing form such as name, local address and mobile number. The other database (the "sensitive database") contains information collected by the HR Department as part of Annual Review Interviews. With the workers' cooperation, this database has expanded to include far-reaching sensitive information such as medical history, religious beliefs, ethnicity and educational levels of immediate family members. Carl left B-Star's employment yesterday, and has flown back home, rendering him unreachable. Today BStar, without Carl's consent, wants to conduct research using Carl's medical records in the sensitive database.Can B-Star legally conduct this research using Carl's medical data?

No, an organization is not allowed to use sensitive personal data without an individual's consent unless absolutely necessary.

Yes, because Carl gave his consent for his sensitive personal data to be collected during his employment.

No, an organization is not allowed to use sensitive personal data without an individual's consent unless absolutely necessary.

No, because the research is taking place after Carl has left B-Star's employment.

Yes, if the research is deemed to be in the public interest.

In June 2011, the Hong Kong Privacy Commissioner determined that data subject consent is NOT valid if it is what?

Bundled with other terms of the agreement.

Provided by the data subject solely in verbal form.

Used for a directly related but separate purpose.

Bundled with other terms of the agreement.

Intended for direct marketing purposes.

Which control is NOT included in the requirements established by the Monetary Authority of Singapore (MAS) for financial institutions in order to deter money-laundering and financial aid to terrorism (AML/ CFT)?

Identifying and knowing customers.

Sharing personal information with the PDPC.

Conducting regular reviews of customer accounts.

Monitoring and reporting suspicious financial transactions.

Which of the following principles of the OECD guidelines and Council of European Convention principles does Singapore's PDPA incorporate?

The ability to opt-out from direct marketing.

Disclosures to third parties included in access requests.

Additional protections for sensitive personal data.

The ability to opt-out from direct marketing.

The right of deletion of data on request.

The "due diligence" exemption in Hong Kong's PDPO was meant to apply to?

Third-party data processors located in foreign countries.

Companies researching the viability of business mergers.

Service providers hosting customer information in the cloud.

Direct marketers acting in the best interest of their company.

What clarification did India make in a 2011 Press Note regarding their Sensitive Personal Data Rules?

That sensitive personal data or information includes passwords, financial information, medical records, and biometric information.

That the rules apply to data subjects located outside of India.

That the rules apply to persons or companies collecting sensitive data within India.

That the data processor must provide notice to the data subject before data is processed.

That sensitive personal data or information includes passwords, financial information, medical records, and biometric information.

Which Hong Kong body has recommended legislation that provides for the right of civil action to be taken when private information is publicly disclosed?

Hong Kong Law Reform Commission.

Hong Kong's Court of Final Appeal.

Hong Kong Law Reform Commission.

Office of the Privacy Commissioner for Personal Data.

Standing Committee of the National People's Congress of the PRC.

Hong Kong's Personal Data (Privacy) Ordinance (PDPO) was primarily inspired by which of the following?

Europe's Data Protection Directive (Directive 95/46/EC).

Macau's Personal Data Protection Act.

South Korea's Public Agency Data Protection Act.

Europe's Data Protection Directive (Directive 95/46/EC).

In which of the following cases would a Singaporean be prevented from accessing information about herself from an organization?

The information is related to an individual's credit rating.

The information was collected in the previous 12 months.

The information is related to an individual's credit rating.

The cost of providing the information proved to be unreasonable.

Any personal information about others has been deleted from the document.

All of the following are guidelines the PDPC gives about anonymised data EXCEPT?

Data that has been anonymised satisfies the "cease to retain" requirement of Section 25.

Anonymised data is not personal data.

Any data that has been anonymised bears the same risks for re-identification.

Data that has been anonymised satisfies the "cease to retain" requirement of Section 25.

Organizations should consider the risk of re-identification if it intends to publish or disclose anonymised data.

A Singapore employer can do all of the following without obtaining an employee's consent EXCEPT?

Share an employee's personal data with a company that provides financial planning.

Disclose personal health data to a public agency during a health crisis.

Use computer monitoring software on an employee's computers.

Use closed-circuit television surveillance in the workplace.

Which Indian institution is vested with powers under the Credit Information Companies (Regulation) Act of 2005?

The Securities and Exchange Board of India.

In what way are Hong Kong citizens protected from direct marketing in ways that India and Singapore citizens are not?

Subscribers must have explicitly indicated that they did not object to their data being collected and used for marketing purposes.

Subscribers can opt out of the use of their data for marketing purposes after collection by withdrawing consent.

Data subjects must be notified on a website if their data is being used for marketing purposes.

Data subjects are protected from the secondary use of personal data for marketing purposes.

SCENARIO – Please use the following to answer the next question:Singabank is a boutique bank in Singapore. After being notified during the hiring process, Singabank employees are subject to constant and thorough monitoring and tracking through CCTV cameras, computer monitoring software and keyboard loggers. Singabank does this to ensure its employees are complying with Singabank's data security policy. Bigbank is now considering acquiring Singabank's retail banking division. As part of its due diligence, Bigbank is seeking for Singabank to disclose to it all of its surveillance material on its employees, whether or not they are part of the retail banking division.Jimmy works in Singabank's investment banking division.Assuming the monitoring was legal, can Singabank disclose Jimmy's personal data to Bigbank?

Yes, if Singabank informs Jimmy of the disclosure of his personal data before it occurs.

No, because Jimmy is not in the division that Bigbank seeks to acquire.

No, because the data was collected for the express purpose of complying with Singabank's privacy policies.

Yes, if Singabank informs Jimmy of the disclosure of his personal data before it occurs.

Yes, if Jimmy's personal data is necessary for Bigbank to determine whether to proceed with the acquisition.

SCENARIO – Please use the following to answer the next question:Bharat Medicals is an established retail chain selling medical goods, with a presence in a number of cities throughout India.Their strategic partnership with major hospitals in these cities helped them capture an impressive market share over the years. However, with lifestyle and demographic shifts in India, the company saw a huge opportunity in door-to-door delivery of essential medical products. The need for such a service was confirmed by an independent consumer survey the firm conducted recently.The company has launched their e-commerce platform in three metro cities, and plans to expand to the rest of the country in the future. Consumers need to register on the company website before they can make purchases. They are required to enter details such as name, age, address, telephone number, sex, date of birth and nationality – information that is stored on the company's servers. (Consumers also have the option of keeping their credit card number on file, so that it does not have to be entered every time they make payment.) If ordered items require a prescription, that authorization needs to be uploaded as well. The privacy notice explicitly requires that the consumer confirm that he or she is either the patient or has consent of the patient for uploading the health information. After creating a unique user ID and password, the consumer's registration will be confirmed through a text message sent to their listed mobile number.To remain focused on their core business, Bharat outsourced the packaging, product dispatch and delivery activities to a third party firm, Maurya Logistics Ltd., with which it has a contractual agreement. It shares with Maurya Logistics the consumer name, address and other product-related details at the time of every purchase.If consumers underwent medical treatment at one of the partner hospitals and consented to having their data transferred, their order requirement will be sent to their Bharat Medicals account directly, thereby doing away with the need to manually place an order for the medications.Bharat Medicals takes regulatory compliance seriously; to ensure data privacy, it displays a privacy notice at the time of registration, and includes all the information that it collects. At this stage of their business, the company plans to store consumer information indefinitely, since the percentage of repeat customers and the frequency of orders per customer is still uncertain.When collecting personal data, Bharat Medicals does NOT need to inform the consumer of what?

The options the subject has to access his data.

The recipients of the collected data.

The name of the body collecting the data.

The type of safeguards protecting the data.

The options the subject has to access his data.

Which method ensures the greatest security when erasing data that is no longer needed, according to the Hong Kong Office of the Privacy Commissioner?

Crosscut shredding paper copies of data.

Strip-shredding paper copies of data.

Crosscut shredding paper copies of data.

Deleting electronic files containing data.

Reformatting USB memory devices containing data.

SCENARIO – Please use the following to answer the next question:Zoe is the new Compliance Manager for the Star Hotel Group, which has five hotels across Hong Kong and China. On her first day, she does an inspection of the largest property, StarOne. She starts with the hotel reception desk. Zoe sees the front desk assistant logging in to a database as he is checking in a guest. The hotel manager, Bernard, tells her that all guest data, including passport numbers, credit card numbers, home address, mobile number and other information associated with a guest's stay is held in a database. Bernard tells her not to worry about the security of the database because it is operated for Star Hotels by a local service provider called HackProof, who therefore are responsible for all the guest data.Zoe notices what looks like a CCTV camera in the corner of the reception area. Bernard says they record all activity in the lobby. In fact, last Tuesday he had received a data access request from a lawyer requesting a copy of footage of all lobby activity for the preceding month. The lawyer's covering letter said that his client has never visited the hotel herself, but is investigating whether her husband has been doing so without her knowledge.Zoe and Bernard head up to the hotel spa. The spa is independently owned by a company called Relax Ltd. Bernard explains that Relax Ltd is a small company and, as they don't have their own database, they transfer data about the spa guests to StarOne staff so that they can upload the data into the HackProof system. Relax Ltd staff can then login and review their guest data as needed.Zoe asks more about the HackProof system. Bernard tells her that the server for the Hong Kong hotels is in Hong Kong, but there is a server in Shenzhen that has a copy of all the Hong Kong hotel data and supports the properties in China. The data is in China for back up purposes and also is accessible by staff in the China hotels so they can better service guests who visit their hotels in both territories.How should Bernard respond to the lawyer's request for the CCTV footage?

Decline to turn over the footage as there is no basis for it to be disclosed under the exemption for prevention or detection of crime.

Decline to turn over the footage as it is not a valid data access request.

Provide a copy of the footage within 40 days as it is a data access request.

Provide a copy of the footage to the lawyer under the exemption for legal professional privilege.

Decline to turn over the footage as there is no basis for it to be disclosed under the exemption for prevention or detection of crime.

Section 43A was amended by India's IT Rules 2011 to include?

A definition of what constitutes reasonable security practices.

A requirement for the creation of a data protection authority.

A list of cases in which privacy policies are not necessary.

A clarification regarding the role of non-automated data.

SCENARIO – Please use the following to answer the next question:Delilah is seeking employment in the marketing department of Good Mining Private Limited, an industry leader in drilling mines in Singapore. Delilah, while filling in the standard paper application form, is asked to provide details about emergency contacts, medical history, blood type and her insurance policy. These fields need to be filled in no matter which department Delilah applies to. The form also asks Delilah to expressly consent to the collection, use and disclosure of her personal data.A week after submitting the form, Delilah is invited by Evan, the Director of Marketing at Good Mining, to coffee. Just before Delilah leaves, she gives her business card containing her current business contact information to Evan. Evan then uses the business card to add Delilah's details to Good Mining's business development database, which is kept on a local server.Good Mining uses the database to inform people about networking and client events that Good Mining organizes.Why is it legal for Evan to add the information on Delilah's business card to the business development database?

Because any business contact information can be freely used, collected or disclosed by Good Mining.

Because Delilah "consented" to her business contact information being used by Good Mining by passing it to Evan voluntarily.

Because any business contact information can be freely used, collected or disclosed by Good Mining.

Because Good Mining does not export the information to a cloud vendor.

Because Delilah initiated the relationship with Good Mining.

Which personal data element is NOT considered a special category of data under the General Data Protection Regulation(GDPR)?

Physical or mental health data.

IAPP CIPP-A Practice Test 2 - Free Online Exam Prep & Questions

Question 1 / 40

Who is NOT potentially liable when an employee in a Singapore corporation or partnership breaches the PDPA?

A corporate officer responsible of setting up data processing.

The employee following the management processes.

The employee's direct manager overseeing data handling.

A partner of the partnership handling data related matters.

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