Question 92 - CIPP-A discussion

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.

What must Dracarys confirm about the vendor in India in order to centralize elements of its Human Resource function?

That the vendor submits for approval from Dracarys a privacy notice explaining how personal data will be protected under the Indian Information Technology Act.

That the vendor files requests for transfer of personal data out of India through the offices of the privacy commissioners of Hong Kong and Singapore.

That the vendor is bound by legally enforceable obligations to provide the personal data a standard of protection that is at least comparable to the protection under the Singapore PDPA.

That the vendor adheres to the same sector privacy rules followed by Dracarys headquarters based in Seattle regarding the transfer of personal data.