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Question 85 - CIPT discussion

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SCENARIO

WebTracker Limited is a cloud-based online marketing service located in London. Last year, WebTracker migrated its IT infrastructure to the cloud provider AmaZure, which provides SQL Databases and Artificial Intelligence services to WebTracker. The roles and responsibilities between the two companies have been formalized in a standard contract, which includes allocating the role of data controller to WebTracker.

The CEO of WebTracker, Mr. Bond, would like to assess the effectiveness of AmaZure's privacy controls, and he recently decided to hire you as an independent auditor. The scope of the engagement is limited only to the marketing services provided by WebTracker, you will not be evaluating any internal data processing activity, such as HR or Payroll.

This ad-hoc audit was triggered due to a future partnership between WebTracker and SmartHome — a partnership that will not require any data sharing. SmartHome is based in the USA, and most recently has dedicated substantial resources to developing smart refrigerators that can suggest the recommended daily calorie intake based on DNA information. This and other personal data is collected by WebTracker.

To get an idea of the scope of work involved, you have decided to start reviewing the company's documentation and interviewing key staff to understand potential privacy risks.

The results of this initial work include the following notes:

There are several typos in the current privacy notice of WebTracker, and you were not able to find the privacy notice for SmartHome.

You were unable to identify all the sub-processors working for SmartHome. No subcontractor is indicated in the cloud agreement with AmaZure, which is responsible for the support and maintenance of the cloud infrastructure.

There are data flows representing personal data being collected from the internal employees of WebTracker, including an interface from the HR system.

Part of the DNA data collected by WebTracker was from employees, as this was a prototype approved by the CEO of WebTracker.

All the WebTracker and SmartHome customers are based in USA and Canada.

Which of the following issues is most likely to require an investigation by the Chief Privacy Officer (CPO) of WebTracker?

A.

Data flows use encryption for data at rest, as defined by the IT manager.

Answers
A.

Data flows use encryption for data at rest, as defined by the IT manager.

B.

AmaZure sends newsletter to WebTracker customers, as approved by the Marketing Manager.

Answers
B.

AmaZure sends newsletter to WebTracker customers, as approved by the Marketing Manager.

C.

Employees' personal data are being stored in a cloud HR system, as approved by the HR Manager.

Answers
C.

Employees' personal data are being stored in a cloud HR system, as approved by the HR Manager.

D.

File Integrity Monitoring is being deployed in SQL servers, as indicated by the IT Architect Manager.

Answers
D.

File Integrity Monitoring is being deployed in SQL servers, as indicated by the IT Architect Manager.

Suggested answer: B

Explanation:

Sending marketing communications such as newsletters to customers involves processing their personal data. It is important for WebTracker's CPO to investigate whether this processing is being done in compliance with applicable data protection laws and regulations. This may include verifying that customers have given their consent to receive these communications or that another lawful basis for processing their personal data exists.

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asked 22/11/2024
Shan Panikker
28 questions
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