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NEW QUESTION 21
SCENARIO
Please use the following to answer the next question:
Liem, an online retailer known for its environmentally friendly shoes, has recently expanded its presence in Europe. Anxious to achieve market dominance, Liem teamed up with another eco friendly company, EcoMick, which sells accessories like belts and bags. Together the companies drew up a series of marketing campaigns designed to highlight the environmental and economic benefits of their products. After months of planning, Liem and EcoMick entered into a data sharing agreement to use the same marketing database, MarketIQ, to send the campaigns to their respective contacts.
Liem and EcoMick also entered into a data processing agreement with MarketIQ, the terms of which included processing personal data only upon Liem and EcoMick’s instructions, and making available to them all information necessary to demonstrate compliance with GDPR obligations.
Liem and EcoMick then procured the services of a company called JaphSoft, a marketing optimization firm that uses machine learning to help companies run successful campaigns. Clients provide JaphSoft with the personal data of individuals they would like to be targeted in each campaign. To ensure protection of its clients’ data, JaphSoft implements the technical and organizational measures it deems appropriate. JaphSoft works to continually improve its machine learning models by analyzing the data it receives from its clients to determine the most successful components of a successful campaign. JaphSoft then uses such models in providing services to its client-base. Since the models improve only over a period of time as more information is collected, JaphSoft does not have a deletion process for the data it receives from clients. However, to ensure compliance with data privacy rules, JaphSoft pseudonymizes the personal data by removing identifying information from the contact information. JaphSoft’s engineers, however, maintain all contact information in the same database as the identifying information.
Under its agreement with Liem and EcoMick, JaphSoft received access to MarketIQ, which included contact information as well as prior purchase history for such contacts, to create campaigns that would result in the most views of the two companies’ websites. A prior Liem customer, Ms. Iman, received a marketing campaign from JaphSoft regarding Liem’s as well as EcoMick’s latest products. While Ms. Iman recalls checking a box to receive information in the future regarding Liem’s products, she has never shopped EcoMick, nor provided her personal data to that company.
JaphSoft’s use of pseudonymization is NOT in compliance with the CDPR because?
- A. JaphSoft failed to first anonymize the personal data.
- B. JaphSoft pseudonymized all the data instead of deleting what it no longer needed.
- C. JaphSoft failed to keep personally identifiable information in a separate database.
- D. JaphSoft was in possession of information that could be used to identify data subjects.
Answer: B
NEW QUESTION 22
What is the most likely reason that states have adopted their own data breach notification laws?
- A. Many types of organizations are not currently subject to federal laws regarding breaches
- B. Many large businesses have intentionally breached the personal information of their customers
- C. Many states have unique types of businesses that require specific legislation
- D. Many lawmakers believe that federal enforcement of current laws has not been effective
Answer: D
NEW QUESTION 23
Federal laws establish which of the following requirements for collecting personal information of minors under the age of 13?
- A. Implied consent from a minor’s parent or guardian before collecting a minor’s personal information online, such as when they permit the minor to use the internet.
- B. Affirmative consent of a parent or guardian before collecting personal information of a minor offline (e.g., in person), which also satisfies any requirements for online consent.
- C. Affirmative consent from a minor’s parent or guardian before collecting the minor’s personal information online.
- D. Implied consent from a minor’s parent or guardian, or affirmative consent from the minor.
Answer: C
NEW QUESTION 24
Which of the following is one of the supervisory authority’s investigative powers?
- A. To require that controllers or processors adopt approved data protection certification mechanisms.
- B. To notify the controller or the processor of an alleged infringement of the GDPR.
- C. To determine whether a controller or processor has the right to a judicial remedy concerning a compensation decision made against them.
- D. To require data controllers to provide them with written notification of all new processing activities.
Answer: B
NEW QUESTION 25
WP29’s “Guidelines on Personal data breach notification under Regulation 2016/679” provides examples of ways to communicate data breaches transparently. Which of the following was listed as a method that would NOT be effective for communicating a breach to data subjects?
- A. A postal notification
- B. A direct electronic message
- C. A prominent advertisement in print media
- D. A notice on a corporate blog
Answer: D
NEW QUESTION 26
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