PECB GDPR Dumps Questions Answers

Scenario 9: Soin is a French travel agency with the largest network of professional travel agents throughout Europe. They aim to create unique vacations for clients regardless of the destinations they seek. The company specializes in helping people find plane tickets, reservations at hotels, cruises, and other activities.

As any other industry, travel is no exception when it comes to GDPR compliance. Soin was directly affected by the enforcement of GDPR since its main activities require the collection and processing of customers’ data. Data collected by Soin includes customer's ID or passport details, financial and payment information, and contact information. This type of data is defined as personal by the GDPR; hence, Soin's data processing activities are built based on customer's consent.

At the beginning, as for many other companies, GDPR compliance was a complicated issue for Soin. However, the process was completed within a few months and later on the company appointed a DPO. Last year, the supervisory authority of France, requested the conduct of a data protection external audit in Soin without an early notice. To ensure GDPR compliance before an external audit was conducted, Soin organized an internal audit. The data protection internal audit was conducted by the DPO of the company. The audit was initiated by firstly confirming the accuracy of records related to all current Soin's data processing activities. The DPO considered that verifying compliance to Article 30 of GDPR would help in defining the data protection internal audit scope. The DPO noticed that not all processing activities of Soin were documented as required by the GDPR. For example, processing activities records of the company did not include a description of transfers of personal data to third countries. In addition, there was no clear description of categories of personal data processed by the company. Other areas that were audited included content of data protection policy, data retention guidelines, how sensitive data is stored, and security policies and practices. The DPO conducted interviews with some employees at different levels of the company. During the audit, the DPO came across some emails sent by Soin's clients claiming that they do not have access in their personal data stored by Soin. Soin's Customer Service Department answered the emails saying that, based on Soin's policies, a client cannot have access to personal data stored by the company. Based on the information gathered, the DPO concluded that there was a lack of employee awareness on the GDPR.

All these findings were documented in the audit report. Once the audit was completed, the DPO drafted action plans to resolve the nonconformities found. Firstly, the DPO created a new procedure which could ensure the right of access to clients. All employees were provided with GDPR compliance awareness sessions. Moreover, the DPO established a document which described the transfer of personal data to third countries and the applicability of safeguards when this transfer is done to an international organization.

Based on this scenario, answer the following question:

To whom should the DPO of Soin report the situations observed during the data protection internal audit?

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 question:

Scenario:

Soyled's customers are required to provide their bank account details to buy a product. According to the GDPR, is this data processing lawful?

Scenario 7:

Scenario 7: EduCCS is an online education platform based in Netherlands. EduCCS helps organizations find, manage, and deliver their corporate training. Most of EduCCS's clients are EU residents. EduCCS is one of the few education organizations that have achieved GDPR compliance since 2019. Their DPO is a full-time employee who has been engaged in most data protection processes within the organization. In addition to facilitating GDPR compliance, the DPO acts as an intermediary point between EduCCS and other relevant interested parties. EduCCS's users can benefit from the variety of up-to-date training library and the possibility of accessing it through their phones, tablets, or computers. EduCCS's services are offered through two main platforms: online learning and digital training. To use one of these platforms, users should sign on EduCCS's website by providing their personal information. Online learning is a platform in which employees of other organizations can search for and request the training they need. Through its digital training platform, on the other hand, EduCCS manages the entire training and education program for other organizations. Organizations that need this type of service need to provide information about their core activities and areas where training sessions are needed. This information is then analyzed by EduCCS and a customized training program is provided. In the beginning, all IT-related services were managed by two employees of EduCCS. However, after acquiring a large number of clients, managing these services became challenging That is why EduCCS decided to outsource the IT service function to X-Tech. X-Tech provides IT support and is responsible for ensuring the security of EduCCS's network and systems. In addition, X-Tech stores and archives EduCCS's information including their training programs and clients' and employees' data. Recently, X-Tech made headlines in the technology press for being a victim of a phishing attack. A group of three attackers hacked X-Tech’s systems via a phishing campaign which targeted the employees of the Marketing Department. By compromising X-Tech's mail server, hackers were able to gain access to more than 200 computer systems. Consequently, access to the networks of EduCCS’s clients was also allowed. Using EduCCS's employee accounts, attackers installed a remote access tool on EduCCS's compromised systems. By doing so, they gained access to personal information of EduCCS's clients, training programs, and other information stored in its online payment system. The attack was detected by X-Tech’s system administrator. After detecting unusual activity in X-Tech’s network, they immediately reported it to the incident management team of the company. One week after being notified about the personal data breach, EduCCS communicated the incident to the supervisory authority with a document that outlined the reasons for the delay revealing that due to the lack of regular testing or modification, their incident response plan was not adequately prepared to handle such an attack. Based on this scenario, answer the following question:

Question:

Which of the following statements best reflects a lesson learned from the scenario?