Which law provides employee benefits, but often mandates the collection of medical information?
What are banks required to do under the Gramm-Leach-Bliley Act (GLBA)?
SCENARIO
Please use the following to answer the next QUESTION :
Matt went into his son's bedroom one evening and found him stretched out on his bed typing on his laptop. ''Doing your network?'' Matt asked hopefully.
''No,'' the boy said. ''I'm filling out a survey.''
Matt looked over his son's shoulder at his computer screen. ''What kind of survey?'' ''It's asking QUESTIONS about my opinions.''
''Let me see,'' Matt said, and began reading the list of QUESTIONS that his son had already answered. ''It's asking your opinions about the government and citizenship. That's a little odd. You're only ten.''
Matt wondered how the web link to the survey had ended up in his son's email inbox. Thinking the message might have been sent to his son by mistake he opened it and read it. It had come from an entity called the Leadership Project, and the content and the graphics indicated that it was intended for children. As Matt read further he learned that kids who took the survey were automatically registered in a contest to win the first book in a series about famous leaders.
To Matt, this clearly seemed like a marketing ploy to solicit goods and services to children. He asked his son if he had been prompted to give information about himself in order to take the survey. His son told him he had been asked to give his name, address, telephone number, and date of birth, and to answer QUESTIONS about his favorite games and toys.
Matt was concerned. He doubted if it was legal for the marketer to collect information from his son in the way that it was. Then he noticed several other commercial emails from marketers advertising products for children in his son's inbox, and he decided it was time to report the incident to the proper authorities.
How could the marketer have best changed its privacy management program to meet COPPA ''Safe Harbor'' requirements?
COPPA safe harbor programs comprise industry groups that self-regulate their member-operators and establish their own guidelines and requirements that must guarantee the same or greater protection for children as the standards set forth in the COPPA rule.
A company based in United States receives information about its UK subsidiary's employees in connection with the centralized HR service it provides.
How can the UK company ensure an adequate level of data protection that would allow the restricted data transfer to continue?
SCCs are for transfers between third parties. BCRs are for intragroup transfers. Post Brexit, company's need to separately obtain approval with the UK ICO for their UK BCRs. 'Holders of EU Binding Corporate Rules (EU BCRs) are now required to take action to continue relying on them as an appropriate safeguard for international data.'
SCENARIO
Please use the following to answer the next QUESTION :
Cheryl is the sole owner of Fitness Coach, Inc., a medium-sized company that helps individuals realize their physical fitness goals through classes, individual instruction, and access to an extensive indoor gym. She has owned the company for ten years and has always been concerned about protecting customer's privacy while maintaining the highest level of service. She is proud that she has built long-lasting customer relationships.
Although Cheryl and her staff have tried to make privacy protection a priority, the company has no formal privacy policy. So Cheryl hired Janice, a privacy professional, to help her develop one.
After an initial assessment, Janice created a first of a new policy. Cheryl read through the draft and was concerned about the many changes the policy would bring throughout the company. For example, the draft policy stipulates that a customer's personal information can only be held for one year after paying for a service such as a session with personal trainer. It also promises that customer information will not be shared with third parties without the written consent of the customer. The wording of these rules worry Cheryl since stored personal information often helps her company to serve her customers, even if there are long pauses between their visits. In addition, there are some third parties that provide crucial services, such as aerobics instructors who teach classes on a contract basis. Having access to customer files and understanding the fitness levels of their students helps instructors to organize their classes.
Janice understood Cheryl's concerns and was already formulating some ideas for revision. She tried to put Cheryl at ease by pointing out that customer data can still be kept, but that it should be classified according to levels of sensitivity. However, Cheryl was skeptical. It seemed that classifying data and treating each type differently would cause undue difficulties in the company's day-to-day operations. Cheryl wants one simple data storage and access system that any employee can access if needed.
Even though the privacy policy was only a draft, she was beginning to see that changes within her company were going to be necessary. She told Janice that she would be more comfortable with implementing the new policy gradually over a period of several months, one department at a time. She was also interested in a layered approach by creating documents listing applicable parts of the new policy for each department.
What is the main problem with Cheryl's suggested method of communicating the new privacy policy?
