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  • Exam Name: PECB Certified Data Protection Officer
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GDPR Questions and Answers

Question # 1

Scenario3:

COR Bank is an international banking group that operates in 31 countries. It was formed as the merger of two well-known investment banks in Germany. Their two main fields of business are retail and investment banking. COR Bank provides innovative solutions for services such as payments, cash management, savings, protection insurance, and real-estate services. COR Bank has a large number of clients and transactions. Therefore, they process large information, including clients' personal data. Some of the data from the application processes of COR Bank, including archived data, is operated by Tibko, an IT services company located in Canada. To ensure compliance with the GDPR, COR Bank and Tibko have reached a data processing agreement Basedon the agreement, the purpose and conditions of data processing are determined by COR Bank. However, Tibko is allowed to make technical decisions for storing the data based on its own expertise. COR Bank aims to remain a trustworthy bank and a long-term partner for its clients. Therefore, they devote special attention to legal compliance. They started the implementation process of a GDPR compliance program in 2018. The first step was to analyze the existing resources and procedures. Lisa was appointed as the data protection officer (DPO). Being the information security manager of COR Bank for many years, Lisa had knowledge of the organization's core activities. She was previously involved in most of the processes related to information systems management and data protection. Lisa played a key role in achieving compliance to the GDPR by advising the company regarding data protection obligations and creating a data protection strategy. After obtaining evidence of the existing data protection policy, Lisa proposed to adapt the policy to specific requirements of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of departments. As the DPO, she had access to several departments, including HR and Accounting Department. This assured the organization that there was a continuous cooperation between them. The activities of some departments within COR Bank are closely related to data protection. Therefore, considering their expertise, Lisa was advised from the top management to take orders from the heads of those departments when taking decisions related to their field. Based on this scenario, answer the following question:

Question:

According to scenario 3,Tibko stores archived data on behalf of COR Bank. This means that Tibko is a:

A.

Data controller, since they control some of the data from the application processes of COR Bank.

B.

Data processor, since they store COR Bank's data based on the purpose and conditions defined by COR Bank.

C.

Joint controller with COR Bank, since they archive COR Bank's data and take technical decisions regarding data protection.

D.

Independent controller, since Tibko handles data security and storage.

Question # 2

Question:

To evaluate theeffectiveness of communication, theDPO of Company ABCreviewed theaccuracy and relevanceof the information provided to customers regarding personal data processing.

Is this agood practiceunder GDPR?

A.

Yes, when evaluating the effectiveness of communication, theDPO should consider the accuracy and relevanceof the information provided to concerned parties.

B.

No, the effectiveness of communicationcannot be evaluatedthrough the evaluation of theaccuracy and relevanceof information provided to customers.

C.

No, the DPO isnot responsiblefor evaluating the effectiveness of communication with customers.

D.

Yes, but only if the company’ssupervisory authority requests it.

Question # 3

Scenario1:

MED is a healthcare provider located in Norway. It provides high-quality and affordable healthcare services, including disease prevention, diagnosis, and treatment. Founded in 1995, MED is one of the largest health organizations in the private sector. The company has constantly evolved in response to patients' needs.

Patients that schedule an appointment in MED's medical centers initially need to provide their personal information, including name, surname, address, phone number, and date of birth. Further checkups or admission require additional information, including previous medical history and genetic data. When providing their personal data, patients are informed that the data is used for personalizing treatments and improving communication with MED's doctors. Medical data of patients, including children, are stored in the database of MED's health information system. MED allows patients who are at least 16 years old to use the system and provide their personal information independently. For children below the age of 16, MED requires consent from the holderof parental responsibility before processing their data.

MED uses a cloud-based application that allows patients and doctors to upload and access information. Patients can save all personal medical data, including test results, doctor visits, diagnosis history, and medicine prescriptions, as well as review and track them at any time. Doctors, on the other hand, can access their patients' data through the application and can add information as needed.

Patients who decide to continue their treatment at another health institution can request MED to transfer their data. However, even if patients decide to continue their treatment elsewhere, their personal data is still used by MED. Patients’ requests to stop data processing are rejected. This decision was made by MED’s top management to retain the information of everyone registered in their databases.

The company also shares medical data with InsHealth, a health insurance company. MED's data helps InsHealth create health insurance plans that meet the needs of individuals and families.

MED believes that it is its responsibility to ensure the security and accuracy of patients’ personal data. Based on the identified risks associated with data processing activities, MED has implemented appropriate security measures to ensure that data is securely stored and processed.

Since personal data of patients is stored and transmitted over the internet, MED uses encryption to avoid unauthorized processing, accidental loss, or destruction of data. The company has established a security policy to define the levels of protection required for each type of information and processing activity. MED has communicated the policy and other procedures to personnel and provided customized training to ensure proper handling of data processing.

Question:

Based on scenario 1, MED shares patients' personal data with a health insurance company. Does MED comply with thepurpose limitation principle?

A.

Yes, personal data may be used for purposes in the public interest or statistical purposes in accordance withArticle 89 of GDPR.

B.

Yes, using personal data for creating health insurance plans is within the scope of the data collection purpose.

C.

No, personal data should be collected for specified, explicit, and legitimate purposes in accordance withArticle 5 of GDPR.

D.

Yes, as long as the data is encrypted before sharing.

Question # 4

Scenario:

Pinky, a retail company,received a requestfrom adata subjectto identify which purchasesthey had madeat differentphysical store locations. However,Pinky does not link purchase records to customer identities, since purchasesdo not require account creation.

Question:

Should Pinkyprocess additional informationfrom customers in order toidentify the data subjectas requested?

A.

Yes, Pinky is required tomaintain, acquire, or process additional informationin order to identify the data subject.

B.

Yes, Pinky is required to process additional information for the purpose ofexercising the data subject’s rightscovered inArticles 15-21 of GDPR.

C.

No, Pinky isnot requiredto process additional information, since the processing of personal data in this case does not require Pinky toidentify the data subject.

D.

No, but Pinky must ask the data subject to provide further evidence proving their identity.

Question # 5

Scenario1:

MED is a healthcare provider located in Norway. It provides high-quality and affordable healthcare services, including disease prevention, diagnosis, and treatment. Founded in 1995, MED is one of the largest health organizations in the private sector. The company has constantly evolved in response to patients' needs.

Patients that schedule an appointment in MED's medical centers initially need to provide their personal information, including name, surname, address, phone number, and date of birth. Further checkups or admission require additional information, including previous medical history and genetic data. When providing their personal data, patients are informed that the data is used for personalizing treatments and improving communication with MED's doctors. Medical data of patients, including children, are stored in the database of MED's health information system. MED allows patients who are at least 16 years old to use the system and provide their personal information independently. For children below the age of 16, MED requires consent from the holder of parental responsibility before processing their data.

MED uses a cloud-based application that allows patients and doctors to upload and access information. Patients can save all personal medical data, including test results, doctor visits, diagnosis history, and medicine prescriptions, as well as review and track them at any time. Doctors, on the other hand, can access their patients' data through the application and can add information as needed.

Patients who decide to continue their treatment at another health institution can request MED to transfer their data. However, even if patients decide to continue their treatment elsewhere, their personal data is still used by MED. Patients’ requests to stop data processing are rejected. This decision was made by MED’s top management to retain the information of everyone registered in their databases.

The company also shares medical data with InsHealth, a health insurance company. MED's data helps InsHealth create health insurance plans that meet the needs of individuals and families.

MED believes that it is its responsibility to ensure the security and accuracy of patients’ personal data. Based on the identified risks associated with data processing activities, MED has implemented appropriate security measures to ensure that data is securely stored and processed.

Since personal data of patients is stored and transmitted over the internet, MED uses encryption to avoid unauthorized processing, accidental loss, or destruction of data. The company has established a security policy to define the levels of protection required for each type of information and processing activity. MED has communicated the policy and other procedures to personnel and provided customized training to ensure proper handling of data processing.

Question:

If a patient requests MED to permanently erase their data, MED should:

A.

Reject the request since the medical history of patients cannot be permanently erased.

B.

Erase the personal data if it is no longer needed for its original purpose.

C.

Erase the personal data only if required to comply with a legal obligation.

D.

Refuse the request because medical data must be retained indefinitely for future reference.

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