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Certified Information Privacy Professional/Europe (CIPP/E)
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With respect to international transfers of personal data, the European Data ProtectionBoard (EDPB) confirmed that derogations may be relied upon under what condition?
After leaving the EU under the terms of Brexit, the United Kingdom will seek an adequacydetermination. What is the reason for this?
Company X has entrusted the processing of their payroll data to Provider Y. Provider Ystores this encrypted data on its server. The IT department of Provider Y finds out thatsomeone managed to hack into the system and take a copy of the data from its server. Inthis scenario, whom does Provider Y have the obligation to notify?
SCENARIOPlease use the following to answer the next question:Brady is a computer programmer based in New Zealand who has been running his ownbusiness for two years. Brady’s business provides a low-cost suite of services to customersthroughout the European Economic Area (EEA). The services are targeted towards newand aspiring small business owners. Brady’s company, called Brady Box, provides webpage design services, a Social Networking Service (SNS) and consulting services that helppeople manage their own online stores.Unfortunately, Brady has been receiving some complaints. A customer named Annarecently uploaded her plans for a new product onto Brady Box’s chat area, which is open topublic viewing. Although she realized her mistake two weeks later and removed thedocument, Anna is holding Brady Box responsible for not noticing the error through regularmonitoring of the website. Brady believes he should not be held liable.Another customer, Felipe, was alarmed to discover that his personal information wastransferred to a third- party contractor called Hermes Designs and worries that sensitiveinformation regarding his business plans may be misused. Brady does not believe heviolated European privacy rules. He provides a privacy notice to all of his customersexplicitly stating that personal data may be transferred to specific third parties in fulfillmentof a requested service. Felipe says he read the privacy notice but that it was long andcomplicatedBrady continues to insist that Felipe has no need to be concerned, as he can personallyvouch for the integrity of Hermes Designs. In fact, Hermes Designs has taken the initiativeto create sample customized banner advertisements for customers like Felipe. Brady ishappy to provide a link to the example banner ads, now posted on the Hermes Designswebpage. Hermes Designs plans on following up with direct marketing to these customers.Brady was surprised when another customer, Serge, expressed his dismay that a quotationby him is being used within a graphic collage on Brady Box’s home webpage. Thequotation is attributed to Serge by first and last name. Brady, however, was not worriedabout any sort of litigation. He wrote back to Serge to let him know that he found thequotation within Brady Box’s Social Networking Service (SNS), as Serge himself hadposted the quotation. In his response, Brady did offer to remove the quotation as acourtesy.Despite some customer complaints, Brady’s business is flourishing. He even supplementshis income through online behavioral advertising (OBA) via a third-party ad network withwhom he has set clearly defined roles. Brady is pleased that, although some customers arenot explicitly aware of the OBA, the advertisements contain useful products and services.Under the General Data Protection Regulation (GDPR), what is the most likely reasonSerge may have grounds to object to the use of his quotation?
According to the GDPR, how is pseudonymous personal data defined?