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Please use the following to answer the next question: ABC Hotel Chain and XYZ Travel Agency are U.S.-based multinational companies. They use an internet-based common platform for collecting and sharing their customer data with each other, in order to integrate their marketing efforts. Additionally, they agree on the data to be stored, how reservations will be booked and confirmed, and who has access to the stored data. Mike, an EU resident, has booked travel itineraries in the past through XYZ Travel Agency to stay at ABC Hotel Chain’s locations. XYZ Travel Agency offers a rewards program that allows customers to sign up to accumulate points that can later be redeemed for free travel. Mike has signed the agreement to be a rewards program member. Now Mike wants to know what personal information the company holds about him. He sends an email requesting access to his data, in order to exercise what he believes are his data subject rights. What is the time period in which Mike should receive a response to his request?
A. Not more than one month of receipt of Mike’s request.
B. Not more than two months after verifying Mike’s identity.
C. When all the information about Mike has been collected.
D. Not more than thirty days after submission of Mike’s request.
A U.S. company’s website sells widgets. Which of the following factors would NOT in itself subject the company to the GDPR?
A. The widgets are offered in EU and priced in euro.
B. The website is in English and French, and is accessible in France.
C. An affiliate office is located in France but the processing is in the U.S.
D. The website places cookies to monitor the EU website user behavior.
Which of the following is NOT considered a fair processing practice in relation to the transparency principle?
A. Providing a multi-layered privacy notice, in a website environment.
B. Providing a QR code linking to more detailed privacy notice, in a CCTV sign.
C. Providing a hyperlink to the organization’s home page, in a hard copy application form.
D. Providing a “just-in-time” contextual pop-up privacy notice, in an online application from field.
An organization conducts body temperature checks as a part of COVID-19 monitoring. Body temperature is measured manually and is not followed by registration, documentationor other processing of an individual’s personal data. Which of the following best explain why this practice would NOT be subject to the GDPR?
A. Body temperature is not considered personal data.
B. The practice does not involve completion by automated means.
C. Body temperature is considered pseudonymous data.
D. The practice is for the purpose of alleviating extreme risks to public health.
Please use the following to answer the next question: Joe started the Gummy Bear Company in 2000 from his home in Vermont, USA. Today, it is a multi-billion-dollar candy company operating in every continent. All of the company’s IT servers are located in Vermont. This year Joe hires his son Ben to join the company and head up Project Big, which is a major marketing strategy to triple gross revenue in just 5 years. Ben graduated with a PhD in computer software from a top university. Ben decided to join his father’s company, but is also secretly working on launching a new global online dating website company called Ben Knows Best. Ben is aware that the Gummy Bear Company has millions of customers and believes that many of them might also be interested in finding their perfect match. For Project Big, Ben redesigns the company’s online web portal and requires customers in the European Union and elsewhere to provide additional personal information in order to remain a customer. Project Ben begins collecting data about customers’ philosophical beliefs, political opinions and marital status. If a customer identifies as single, Ben then copies all of that customer’s personal data onto a separate database for Ben Knows Best. Ben believes that he is not doing anything wrong, because he explicitly asks each customer to give their consent by requiring them to check a box before accepting their information. As Project Big is an important project, the company also hires a first year college student named Sam, who is studying computer science to help Ben out. Ben calls out and Sam comes across the Ben Knows Best database. Sam is planning on going to Ireland over Spring Beak with 10 of his friends, so he copies all of the customer information of people that reside in Ireland so that he and his friends can contact people when they are in Ireland. Joe also hires his best friend’s daughter, Alice, who just graduated from law school in the U.S., to be the company’s new General Counsel. Alice has heard about the GDPR, so she does some research on it. Alice approaches Joe and informs him that she has drafted up Binding Corporate Rules for everyone in the company to follow, as it is important for the company to have in place a legal mechanism to transfer data internally from the company’s operations in the European Union to the U.S. Joe believes that Alice is doing a great job, and informs her that she will also be in-charge of handling a major lawsuit that has been brought against the company in federal court in the U.S. To prepare for the lawsuit, Alice instructs the company’s IT department to make copies of the computer hard drives from the entire global sales team, including the European Union, and send everything to her so that she can review everyone’s information. Alice believes that Joe will be happy that she did the first level review, as it will save the company a lot of money that would otherwise be paid to its outside law firm. In preparing the company for its impending lawsuit, Alice’s instruction to the company’s IT Department violated Article 5 of the GDPR because the company failed to first do what?
A. Send out consent forms to all of its employees.
B. Minimize the amount of data collected for the lawsuit.
C. Inform all of its employees about the lawsuit.
D. Encrypt the data from all of its employees.