Scenario: 2
Soyled is a retail company that sells a wide range of electronic products from top European brands. It primarily sells its products in its online platforms (which include customer reviews and ratings), despite using physical stores since 2015. Soyled's website and mobile app are used by millions of customers. Soyled has employed various solutions to create a customer-focused ecosystem and facilitate growth. Soyled uses customer relationship management (CRM) software to analyze user data and administer the interaction with customers. The software allows the company to store customer information, identify sales opportunities, and manage marketing campaigns. It automatically obtains information about each user's IP address and web browser cookies. Soyled also uses the software to collect behavioral data, such as users' repeated actions and mouse movement information. Customers must create an account to buy from Soyled's online platforms. To do so, they fill out a standard sign-up form of three mandatory boxes (name, surname, email address) and a non-mandatory one (phone number). When the user clicks the email address box, a pop-up message appears as follows: ''Soyled needs your email address to grant you access to your account and contact you about any changes related to your account and our website. For further information, please read our privacy policy.' When the user clicks the phone number box, the following message appears: ''Soyled may use your phone number to provide text updates on the order status. The phone number may also be used by the shipping courier." Once the personal data is provided, customers create a username and password, which are used to access Soyled's website or app. When customers want to make a purchase, they are also required to provide their bank account details. When the user finally creates the account, the following message appears: ''Soyled collects only the personal data it needs for the following purposes: processing orders, managing accounts, and personalizing customers' experience. The collected data is shared with our network and used for marketing purposes." Soyled uses personal data to promote sales and its brand. If a user decides to close the account, the personal data is still used for marketing purposes only. Last month, the company received an email from John, a customer, claiming that his personal data was being used for purposes other than those specified by the company. According to the email, Soyled was using the data for direct marketing purposes. John requested details on how his personal data was collected, stored, and processed. Based on this scenario, answer the following Questio n:
Questio n:
Based on scenario 2, Soyled only has three mandatory fields in its sign-up form. On which GDPR principle is this decision based?
Under Article 5(1)(c) of GDPR, the data minimization principle states that personal data must be adequate, relevant, and limited to what is necessary for processing.
Soyled's decision to have only three mandatory fields (name, surname, and email) aligns with data minimization since it only collects the minimum data needed for account creation. Option C is correct. Option A is incorrect as transparency relates to informing users. Option B is incorrect because purpose limitation focuses on using data only for specific purposes. Option D is incorrect because storage limitation concerns data retention periods.
GDPR Article 5(1)(c) (Data minimization principle)
Recital 39 (Limiting data collection to necessity)
Scenario 5:
Recpond is a German employment recruiting company. Their services are delivered globally and include consulting and staffing solutions. In the beginning. Recpond provided its services through an office in Germany. Today, they have grown to become one of the largest recruiting agencies, providing employment to more than 500,000 people around the world. Recpond receives most applications through its website. Job searchers are required to provide the job title and location. Then, a list of job opportunities is provided. When a job position is selected, candidates are required to provide their contact details and professional work experience records. During the process, they are informed that the information will be used only for the purposes and period determined by Recpond. Recpond's experts analyze candidates' profiles and applications and choose the candidates that are suitable for the job position. The list of the selected candidates is then delivered to Recpond's clients, who proceed with the recruitment process. Files of candidates that are not selected are stored in Recpond's databases, including the personal data of candidates who withdraw the consent on which the processing was based. When the GDPR came into force, the company was unprepared. The top management appointed a DPO and consulted him for all data protection issues. The DPO, on the other hand, reported the progress of all data protection activities to the top management. Considering the level of sensitivity of the personal data processed by Recpond, the DPO did not have direct access to the personal data of all clients, unless the top management deemed it necessary. The DPO planned the GDPR implementation by initially analyzing the applicable GDPR requirements. Recpond, on the other hand, initiated a risk assessment to understand the risks associated with processing operations. The risk assessment was conducted based on common risks that employment recruiting companies face. After analyzing different risk scenarios, the level of risk was determined and evaluated. The results were presented to the DPO, who then decided to analyze only the risks that have a greater impact on the company. The DPO concluded that the cost required for treating most of the identified risks was higher than simply accepting them. Based on this analysis, the DPO decided to accept the actual level of the identified risks. After reviewing policies and procedures of the company. Recpond established a new data protection policy. As proposed by the DPO, the information security policy was also updated. These changes were then communicated to all employees of Recpond. Based on this scenario, answer the following Questio n:
Questio n:
Recpond stores files of candidates who are not selected in its databases, even if they withdraw consent. Is this acceptable under GDPR?
Under Article 17 of GDPR (Right to Erasure), data subjects have the right to request deletion of their personal data when consent is withdrawn, unless a legal obligation or legitimate interest requires retention.
Option A is correct because Recpond must erase personal data if consent is withdrawn and no other lawful basis exists.
Option B is incorrect because GDPR requires deletion, not just stopping processing.
Option C is incorrect because organizations cannot retain data for future purposes without an explicit legal basis.
Option D is incorrect because statistical use must involve anonymization, which is not mentioned in Recpond's process.
GDPR Article 17(1)(b) (Right to be forgotten when consent is withdrawn)
Recital 65 (Obligation to erase personal data when processing is no longer necessary)
Which statement below regarding the difference between anonymization and pseudonymization is correct?
According to GDPR Recital 26, anonymization permanently removes any possibility of re-identification, making it irreversible. Pseudonymization, as defined in Article 4(5), is reversible if the correct key or additional information is available. Pseudonymization still qualifies as personal data under GDPR, whereas anonymized data falls outside the scope of GDPR.
An organization suffered a personal data breach. The attackers gained access to their database through a user account that had unlimited access to dat
a. What should the DPO advise the organization to do in order to prevent the recurrence of similar scenarios?
GDPR Article 32(1)(b) emphasizes implementing access controls to ensure data security. Reviewing and restricting account permissions using the principle of least privilege (PoLP) helps prevent unauthorized access. Shared accounts (option C) increase security risks, and using cloud computing (option B) does not directly address access control vulnerabilities.
When pseudonymization is used in a dataset, the data is divided into restricted access data and non-identifiable dat
a. This restricted access data includes gender, occupation, and age, whereas the non-identifiable data includes only nationality. Is this correct?
Pseudonymization does not remove data identifiability but rather reduces the direct link to an individual (GDPR Article 4(5)). Non-identifiable data includes attributes like gender and occupation, whereas restricted access data includes directly identifying details such as names. Anonymization, not pseudonymization, ensures complete irreversibility.
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