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Jerry the Chief Marketing Officer for a sports apparel and trophy company, sells products to schools and athletic clubs globally Recently the company has decided to invest in a new line of customized sports equipment Jerry plans to email his current customer base to offer them a discount on their first purchase of such equipment. Jerry tells Kate, the Director of Privacy, about his plan. What is the best guidance Kate can provide to Jerry?
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The Planet 49 CJEU Judgement applies to?
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SCENARIO Please use the following to answer the next question: Brady is a computer programmer based in New Zealand who has been running his own business for two years. Brady's business provides a low-cost suite of services to customers throughout the European Economic Area (EEA). The services are targeted towards new and aspiring small business owners. Brady's company, called Brady Box, provides web page design services, a Social Networking Service (SNS) and consulting services that help people manage their own online stores. Unfortunately, Brady has been receiving some complaints. A customer named Anna recently uploaded her plans for a new product onto Brady Box's chat area, which is open to public viewing. Although she realized her mistake two weeks later and removed the document, Anna is holding Brady Box responsible for not noticing the error through regular monitoring of the website. Brady believes he should not be held liable. Another customer, Felipe, was alarmed to discover that his personal information was transferred to a third- party contractor called Hermes Designs and worries that sensitive information regarding his business plans may be misused. Brady does not believe he violated European privacy rules. He provides a privacy notice to all of his customers explicitly stating that personal data may be transferred to specific third parties in fulfillment of a requested service. Felipe says he read the privacy notice but that it was long and complicated Brady continues to insist that Felipe has no need to be concerned, as he can personally vouch for the integrity of Hermes Designs. In fact, Hermes Designs has taken the initiative to create sample customized banner advertisements for customers like Felipe. Brady is happy to provide a link to the example banner ads, now posted on the Hermes Designs webpage. Hermes Designs plans on following up with direct marketing to these customers. Brady was surprised when another customer, Serge, expressed his dismay that a quotation by him is being used within a graphic collage on Brady Box's home webpage. The quotation is attributed to Serge by first and last name. Brady, however, was not worried about any sort of litigation. He wrote back to Serge to let him know that he found the quotation within Brady Box's Social Networking Service (SNS), as Serge himself had posted the quotation. In his response, Brady did offer to remove the quotation as a courtesy. Despite some customer complaints, Brady's business is flourishing. He even supplements his income through online behavioral advertising (OBA) via a third-party ad network with whom he has set clearly defined roles. Brady is pleased that, although some customers are not explicitly aware of the OBA, the advertisements contain useful products and services. Under the General Data Protection Regulation (GDPR), what is the most likely reason Serge may have grounds to object to the use of his quotation?

Question 195 - CIPP-E discussion

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According to the European Data Protection Board, which of the following concepts or practices does NOT follow from the principles relating to the processing of personal data under EU data protection law?

A.

Data ownership allocation.

Answers
A.

Data ownership allocation.

B.

Access control management.

Answers
B.

Access control management.

C.

Frequent pseudonymization key rotation.

Answers
C.

Frequent pseudonymization key rotation.

D.

Error propagation avoidance along the processing chain.

Answers
D.

Error propagation avoidance along the processing chain.

Suggested answer: A

Explanation:

According to the European Data Protection Board, the principles relating to the processing of personal data under EU data protection law are: lawfulness, fairness and transparency; purpose limitation; data minimization; accuracy; storage limitation; integrity and confidentiality; and accountability1.These principles imply certain concepts or practices that data controllers and processors should follow, such as access control management, frequent pseudonymization key rotation, and error propagation avoidance along the processing chain2.However, data ownership allocation is not a concept or practice that follows from these principles, as the GDPR does not recognize the notion of data ownership by either the data subject or the data controller3. Therefore, option A is the correct answer.Reference:

Data protection basics

Guidelines 2/2019 on the processing of personal data under Article 6(1)(b) GDPR in the context of the provision of online services to data subjects

CIPP/E Study Guide, page 11

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asked 22/11/2024
Francisco Jesús Cano Hinarejos
53 questions
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