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Scenario:
BookSt is an online bookshop that collects personal data before selling its products. Sarah signed up for an account, providing her name, email, and password. To purchase a book, Sarah was required to provide her shipping address and payment information, which is needed to calculate shipping costs and complete the transaction.
Questio n:
Does the company have a legal basis for processing Sarah's data?
GDPR Article 6(1)(b) (Processing necessary for contract performance)
Recital 44 (Contractual necessity as a legal basis)
Bus Spot is one of the largest bus operators in Spain. The company operates in local transport and bus rental since 2009. The success of Bus Spot can be attributed to the digitization of the bus ticketing system, through which clients can easily book tickets and stay up to date on any changes to their arrival or departure time. In recent years, due to the large number of passengers transported daily. Bus Spot has dealt with different incidents including vandalism, assaults on staff, and fraudulent injury claims. Considering the severity of these incidents, the need for having strong security measures had become crucial. Last month, the company decided to install a CCTV system across its network of buses. This security measure was taken to monitor the behavior of the company's employees and passengers, enabling crime prevention and ensuring safety and security. Following this decision, Bus Spot initiated a data protection impact assessment (DPIA). The outcome of each step of the DPIA was documented as follows: Step 1: In all 150 buses, two CCTV cameras will be installed. Only individuals authorized by Bus Spot will have access to the information generated by the CCTV system. CCTV cameras capture images only when the Bus Spot's buses are being used. The CCTV cameras will record images and sound. The information is transmitted to a video recorder and stored for 20 days. In case of incidents, CCTV recordings may be stored for more than 40 days and disclosed to a law enforcement body. Data collected through the CCTV system will be processed bv another organization. The purpose of processing this tvoe of information is to increase the security and safety of individuals and prevent criminal activity. Step 2: All employees of Bus Spot were informed for the installation of a CCTV system. As the data controller, Bus Spot will have the ultimate responsibility to conduct the DPI
Under Article 35(11) of GDPR, controllers must reassess DPIAs regularly to account for changing risks in processing activities like CCTV surveillance.
Option D is correct because CCTV monitoring poses an ongoing risk, requiring periodic DPIA reviews.
Option A is incorrect because regular DPIA reviews are required, even if the data processing remains the same.
Option B is incorrect because transparency is a key principle of GDPR, and displaying information does not breach GDPR.
Option C is incorrect because data processors can process CCTV data as long as there is a processing agreement (Article 28).
GDPR Article 35(11) (Periodic DPIA review)
Recital 90 (Regular assessment of risks)
Scenario:
Pinky, a retail company, received a request from a data subject to identify which purchases they had made at different physical store locations. However, Pinky does not link purchase records to customer identities, since purchases do not require account creation.
Questio n:
Should Pinky process additional information from customers in order to identify the data subject as requested?
Under Article 11(1) of GDPR, controllers are not required to process additional data for the sole purpose of identifying data subjects if such identification is not needed for processing.
Option C is correct because Pinky does not store identifiable purchase data, so it is not required to create additional records.
Option A and B are incorrect because GDPR does not obligate controllers to process additional data if identification is unnecessary.
Option D is incorrect because Pinky cannot require additional information when it does not have a basis to process identity-linked data.
GDPR Article 11(1) (Controllers are not required to process extra data for identification)
Recital 57 (Data controllers should avoid collecting unnecessary identity data)
Scenario 8: MA store is an online clothing retailer founded in 2010. They provide quality products at a reasonable cost. One thing that differentiates MA store from other online shopping sites is their excellent customer service.
MA store follows a customer-centered business approach. They have created a user-friendly website with well-organized content that is accessible to everyone. Through innovative ideas and services, MA store offers a seamless user experience for visitors while also attracting new customers. When visiting the website, customers can filter their search results by price, size, customer reviews, and other features. One of MA store's strategies for providing, personalizing, and improving its products is data analytics. MA store tracks and analyzes the user actions on its website so it can create customized experience for visitors.
In order to understand their target audience, MA store analyzes shopping preferences of its customers based on their purchase history. The purchase history includes the product that was bought, shipping updates, and payment details. Clients' personal data and other information related to MA store products included in the purchase history are stored in separate databases. Personal information, such as clients' address or payment details, are encrypted using a public key. When analyzing the shopping preferences of customers, employees access only the information about the product while the identity of customers is removed from the data set and replaced with a common value, ensuring that customer identities are protected and cannot be retrieved.
Last year, MA store announced that they suffered a personal data breach where personal data of clients were leaked. The personal data breach was caused by an SQL injection attack which targeted MA store's web application. The SQL injection was successful since no parameterized queries were used.
Based on this scenario, answer the following Questio n:
According to scenario 8, MA store analyzed shopping preferences of its customers by analyzing the product they have bought in the customer's purchase history. Which option is correct in this case?
Since the data is pseudonymized (not fully anonymized), it remains personal data under GDPR and cannot be retained indefinitely. Article 5(1)(e) of GDPR states that personal data must be kept only for as long as necessary for the intended processing purpose. Additionally, Recital 26 of GDPR clarifies that pseudonymized data is still considered personal data if re-identification is possible. Therefore, MA Store must implement a retention policy that ensures the data is deleted or further anonymized once it is no longer needed for analysis.
Bus Spot is one of the largest bus operators in Spain. The company operates in local transport and bus rental since 2009. The success of Bus Spot can be attributed to the digitization of the bus ticketing system, through which clients can easily book tickets and stay up to date on any changes to their arrival or departure time. In recent years, due to the large number of passengers transported daily. Bus Spot has dealt with different incidents including vandalism, assaults on staff, and fraudulent injury claims. Considering the severity of these incidents, the need for having strong security measures had become crucial. Last month, the company decided to install a CCTV system across its network of buses. This security measure was taken to monitor the behavior of the company's employees and passengers, enabling crime prevention and ensuring safety and security. Following this decision, Bus Spot initiated a data protection impact assessment (DPIA). The outcome of each step of the DPIA was documented as follows: Step 1: In all 150 buses, two CCTV cameras will be installed. Only individuals authorized by Bus Spot will have access to the information generated by the CCTV system. CCTV cameras capture images only when the Bus Spot's buses are being used. The CCTV cameras will record images and sound. The information is transmitted to a video recorder and stored for 20 days. In case of incidents, CCTV recordings may be stored for more than 40 days and disclosed to a law enforcement body. Data collected through the CCTV system will be processed bv another organization. The purpose of processing this tvoe of information is to increase the security and safety of individuals and prevent criminal activity. Step 2: All employees of Bus Spot were informed for the installation of a CCTV system. As the data controller, Bus Spot will have the ultimate responsibility to conduct the DPI
Under Article 5(1)(a) of GDPR, personal data must be processed lawfully, fairly, and transparently. Bus Spot implemented measures such as employee training and signage in buses, which reduced risks associated with transparency.
Option A is correct because Bus Spot took steps to reduce risk, such as clear notification signs and restricted CCTV access.
Option B is incorrect because risk retention means accepting the risk without mitigation, which Bus Spot did not do.
Option C is incorrect because risk transfer applies to outsourcing responsibilities (e.g., insurance), which is not the case here.
Option D is incorrect because Bus Spot did not avoid risk entirely; they implemented controls to mitigate it.
GDPR Article 5(1)(a) (Principle of lawfulness, fairness, and transparency)
Recital 39 (Transparency in data processing)
