IAPP CIPP-A Practice Test - Questions Answers, Page 6
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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.
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 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.
Sending offensive messages.
In the area of human rights, what separates Singapore from many other Asian countries?
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:
The recruitment process;
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?
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?
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.
On what group does Singapore's PDPA impose disclosure restrictions that Hong Kong and India do not?
Government officials.
Children under 13.
The deceased.
The clergy.
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.
Cases in which an Indian company is accused of violating provisions of India's IT Act must be heard by?
The High Court.
A Grievance Officer.
An Adjudicating Officer.
The Cyber Appellate Tribunal.
Which of the following principles of the OECD guidelines and Council of European Convention principles does Singapore's PDPA incorporate?
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.
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