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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. Members of Relax Ltd's staff are concerned about the data sharing with StarOne. How should Zoe respond to their concerns?


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?


SCENARIO – Please use the following to answer the next question: Fitness For Everyone ("FFE") is a gym on Hong Kong Island that is affiliated with a network of gyms throughout Southeast Asia. When prospective members of the gym stop in, call in or submit an inquiry online, they are invited for a free trial session. At first, the gym asks prospective clients only for basic information: a full name, contact number, age and their Hong Kong ID number, so that FFE's senior trainer Kelvin can reach them to arrange their first appointment. One day, a potential customer named Stephen took a tour of the gym with Kelvin and then decided to join FFE for six months. Kelvin pulled out a registration form and explained FFE's policies, placing a circle next to the part that read "FEE and affiliated third parties" may market new products and services using the contact information provided on the form to Stephen "for the duration of his membership." Stephen asked if he could opt-out of the marketing communications. Kelvin shrugged and said that it was a standard part of the contract and that most gyms have it, but that even so Kelvin's manager wanted the item circled on all forms. Stephen agreed, signed the registration form at the bottom of the page, and provided his credit card details for a monthly gym fee. He also exchanged instant messenger/cell details with Kelvin so that they could communicate about personal training sessions scheduled to start the following week. After attending the gym consistently for six months, Stephen's employer transferred him to another part of the Island, so he did not renew his FFE membership. One year later, Stephen started to receive numerous text messages each day from unknown numbers, most marketing gym or weight loss products. Suspecting that FFE shared his information widely, he contacted his old FFE branch and asked reception if they still had his information on file. They did, but offered to delete it if he wished. He was told FFE's process to purge his information from all the affiliated systems might take 8 to 12 weeks. FFE also informed him that Kelvin was no longer employed by FFE and had recently started working for a competitor. FFE believed that Kelvin may have shared the mobile contact details of his clients with the new gym, and apologized for this inconvenience. Assuming that Kelvin received a commission for sharing his former client list with the new employer, and the new employer used Stephen's data to engage in direct marketing to Stephen, which of the following penalties could Kelvin face under Part VI A of the Ordinance?


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

A.

A corporate officer responsible of setting up data processing.

A.

A corporate officer responsible of setting up data processing.

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B.

The employee following the management processes.

B.

The employee following the management processes.

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C.

The employee's direct manager overseeing data handling.

C.

The employee's direct manager overseeing data handling.

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D.

A partner of the partnership handling data related matters.

D.

A partner of the partnership handling data related matters.

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Suggested answer: A

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:

A.

The recruitment process;

A.

The recruitment process;

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B.

Employee assessment and records management;

B.

Employee assessment and records management;

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C.

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?

C.

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?

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D.

Breach notification.

D.

Breach notification.

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E.

Data retention periods.

E.

Data retention periods.

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F.

Employee recruitment process.

F.

Employee recruitment process.

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G.

Data subject consent provisions.

G.

Data subject consent provisions.

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Suggested answer: D

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

A.

Deal with sensitive personal data.

A.

Deal with sensitive personal data.

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B.

Conduct cross-border data transfers.

B.

Conduct cross-border data transfers.

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C.

Are considered part of the public sector.

C.

Are considered part of the public sector.

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D.

Lack alternate enforcement mechanisms.

D.

Lack alternate enforcement mechanisms.

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Suggested answer: A

Explanation:

Reference: https://taxguru.in/corporate-law/compliance-relation-appointment-grievance-officer-provisions-informationtechnology-act-2000.html

What does NOT need to be considered when determining the retention schedule for sensitive personal data?

A.

Business needs.

A.

Business needs.

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B.

Amount of data.

B.

Amount of data.

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C.

Storage capacity.

C.

Storage capacity.

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D.

Regulatory requirements.

D.

Regulatory requirements.

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Suggested answer: C

Explanation:

Reference: https://www.itgovernance.co.uk/blog/top-tips-for-data-retention-under-the-gdpr

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?

A.

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

A.

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

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B.

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

B.

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

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C.

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

C.

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

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D.

Immediately gather essential information in relation to the breach.

D.

Immediately gather essential information in relation to the breach.

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Suggested answer: B

Explanation:

Reference: https://www.pcpd.org.hk/english/resources_centre/publications/files/DataBreachHandling2015_e.pdf

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

A.

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

A.

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

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B.

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

B.

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

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C.

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

C.

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

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D.

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

D.

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

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Suggested answer: B

Explanation:

Reference: https://www.oecd.org/sti/ieconomy/oecd_privacy_framework.pdf (page 3)

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?

A.

It was restricted to residents of India.

A.

It was restricted to residents of India.

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B.

It was necessary for proving citizenship.

B.

It was necessary for proving citizenship.

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C.

It was required in order to obtain government services.

C.

It was required in order to obtain government services.

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D.

It was used to gather information to discriminate against minorities.

D.

It was used to gather information to discriminate against minorities.

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Suggested answer: A

Explanation:

Reference: https://indiankanoon.org/doc/127517806/

Although the right to privacy is not explicitly granted in the Indian Constitution, privacy advocates frequently cite Article 21's guarantee of?

A.

Personal liberty.

A.

Personal liberty.

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B.

Right to property.

B.

Right to property.

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C.

Equality before the law.

C.

Equality before the law.

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D.

Freedom from intrusion.

D.

Freedom from intrusion.

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Suggested answer: A

Explanation:

Reference: https://thewire.in/law/supreme-court-aadhaar-right-to-privacy

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

A.

Messages that promote investment opportunities.

A.

Messages that promote investment opportunities.

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B.

Messages that conduct market research.

B.

Messages that conduct market research.

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C.

Messages from charitable organizations.

C.

Messages from charitable organizations.

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D.

Messages from political candidates.

D.

Messages from political candidates.

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Suggested answer: B

Explanation:

Reference: https://www.pdpc.gov.sg/-/media/Files/PDPC/PDF-Files/Advisory-Guidelines/Advisory-Guidelines-on-the-DNCProvisions-1-Feb-2021.pdf?la=en

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

A.

It should be available and produced on request.

A.

It should be available and produced on request.

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B.

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

B.

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

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C.

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

C.

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

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D.

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

D.

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

Answers
Suggested answer: A

Explanation:

Reference: https://www.mondaq.com/india/privacy-protection/904916/a-review-of-the-information-technology-rules-2011-

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