After committing to a Privacy by Design program, which activity should take place first?
SCENARIO
Please use the following to answer the next questions:
Your company is launching a new track and trace health app during the outbreak of a virus pandemic in the US. The developers claim the app is based on privacy by design because personal data collected was considered to ensure only necessary data is captured, users are presented with a privacy notice, and they are asked to give consent before data is shared. Users can update their consent after logging into an account, through a dedicated privacy and consent hub. This is accessible through the 'Settings' icon from any app page, then clicking 'My Preferences', and selecting 'Information Sharing and Consent' where the following choices are displayed:
* "I consent to receive notifications and infection alerts";
* "I consent to receive information on additional features or services, and new products";
* "I consent to sharing only my risk result and location information, for exposure and contact tracing purposes";
* "I consent to share my data for medical research purposes"; and
* "I consent to share my data with healthcare providers affiliated to the company".
For each choice, an ON* or OFF tab is available The default setting is ON for all
Users purchase a virus screening service for USS29 99 for themselves or others using the app The virus screening
service works as follows:
* Step 1 A photo of the user's face is taken.
* Step 2 The user measures their temperature and adds the reading in the app
* Step 3 The user is asked to read sentences so that a voice analysis can detect symptoms
* Step 4 The user is asked to answer questions on known symptoms
* Step 5 The user can input information on family members (name date of birth, citizenship, home address, phone number, email and relationship).)
The results are displayed as one of the following risk status "Low. "Medium" or "High" if the user is deemed at "Medium " or "High" risk an alert may be sent to other users and the user is Invited to seek a medical consultation and diagnostic from a healthcare provider.
A user's risk status also feeds a world map for contact tracing purposes, where users are able to check if they have been or are in dose proximity of an infected person If a user has come in contact with another individual classified as "medium' or 'high' risk an instant notification also alerts the user of this. The app collects location trails of every user to monitor locations visited by an infected individual Location is collected using the phone's GPS functionary, whether the app is in use or not however, the exact location of the user is "blurred' for privacy reasons Users can only see on the map circles
Which technology is best suited for the contact tracing feature of the app1?
Bluetooth technology can enable devices to communicate with each other over short distances. This makes it well-suited for contact tracing applications where proximity between individuals needs to be detected. Deep learning (option B), Near Field Communication (NFC) (option C), and Radio-Frequency Identification (RFID) (option D) are technologies that could also have potential uses in a contact tracing app but may not be as well-suited as Bluetooth.
A user who owns a resource wants to give other individuals access to the resource. What control would apply?
SCENARIO
Please use the following to answer the next question:
Jordan just joined a fitness-tracker start-up based in California, USA, as its first Information Privacy and Security Officer. The company is quickly growing its business but does not sell any of the fitness trackers itself. Instead, it relies on a distribution network of third-party retailers in all major countries. Despite not having any stores, the company has a 78% market share in the EU. It has a website presenting the company and products, and a member section where customers can access their information. Only the email address and physical address need to be provided as part of the registration process in order to customize the site to the user's region and country. There is also a newsletter sent every month to all members featuring fitness tips, nutrition advice, product spotlights from partner companies based on user behavior and preferences.
Jordan says the General Data Protection Regulation (GDPR) does not apply to the company. He says the company is not established in the EU, nor does it have a processor in the region. Furthermore, it does not do any ''offering goods or services'' in the EU since it does not do any marketing there, nor sell to consumers directly. Jordan argues that it is the customers who chose to buy the products on their own initiative and there is no ''offering'' from the company.
The fitness trackers incorporate advanced features such as sleep tracking, GPS tracking, heart rate monitoring. wireless syncing, calorie-counting and step-tracking. The watch must be paired with either a smartphone or a computer in order to collect data on sleep levels, heart rates, etc. All information from the device must be sent to the company's servers in order to be processed, and then the results are sent to the smartphone or computer. Jordan argues that there is no personal information involved since the company does not collect banking or social security information.
Why is Jordan's claim that the company does not collect personal information as identified by the GDPR inaccurate?
Sleep and heart rate data collected by the fitness trackers can be considered personal information under the GDPR because it relates to an identified or identifiable natural person. This means that even if the company does not collect other types of personal information such as name or address, it is still collecting personal information as defined by the GDPR.
What is the most effective first step to take to operationalize Privacy by Design principles in new product development and projects?
This is the most effective first step to operationalize Privacy by Design principles in new product development and projects. It is important to obtain leadership buy-in for a mandatory privacy review and approval process to ensure that privacy is a priority throughout the organization.
