PECB GDPR 問題集

質問 1：
Scenario:
Bankbiois a financial institution that handlespersonal dataof its customers. Itsdata processing activities involve processingthat is necessary for thelegitimate interestspursued by the institution. In such cases, Bankbio processes personal datawithout obtaining consent from data subjects.
Question:
Is the data processinglawful under GDPR?
A. Yes, processing is lawful when it is necessary for thelegitimate interestspursued by the controller, except where such interests are overridden by the interests of fundamental rights.
B. No, the processing is lawfulonly if the data subject has given explicit consentto the processing of personal data for the specified purpose.
C. Yes, GDPR allows the processing of personal data for thelegitimate interest pursued by the controller or by a third party in all cases.
D. No, financial institutionsmust always obtain explicit consentbefore processing personal data.
正解：A
解説: (Topexam メンバーにのみ表示されます)

質問 2：
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'scompromised 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:
Based on scenario 7, didEduCCS comply with GDPRregardingdata breach notification requirements?
A. No, EduCCS' notification to thesupervisory authorityafterone weekviolates GDPR's requirementfor timely notification.
B. Yes, EduCCS actedin compliancewith GDPR bynotifying the supervisory authority one week after the violation.
C. Yes, EduCCS wasnot obligated to notifythe supervisory authority about the breach, since it occurred at itsIT service provider, X-Tech.
D. No, EduCCS should havereported the breach directly to affected clientsbefore informing the supervisory authority.
正解：A
解説: (Topexam メンバーにのみ表示されます)

質問 3：
Scenario3:
COR Bank is an international banking group that operates in 31 countries. It was formed as the merger of two well-known investment banks in Germany. Their two main fields of business are retail and investment banking. COR Bank provides innovative solutions for services such as payments, cash management, savings, protection insurance, and real-estate services. COR Bank has a large number of clients and transactions.
Therefore, they process large information, including clients' personal data. Some of the data from the application processes of COR Bank, including archived data, is operated by Tibko, an IT services company located in Canada. To ensure compliance with the GDPR, COR Bank and Tibko have reached a data processing agreement Basedon the agreement, the purpose and conditions of data processing are determined by COR Bank. However, Tibko is allowed to make technical decisions for storing the data based on its own expertise. COR Bank aims to remain a trustworthy bank and a long-term partner for its clients. Therefore, they devote special attention to legal compliance. They started the implementation process of a GDPR compliance program in 2018. The first step was to analyze the existing resources and procedures. Lisa was appointed as the data protection officer (DPO). Being the information security manager of COR Bank for many years, Lisa had knowledge of the organization's core activities. She was previously involved in most of the processes related to information systems management and data protection. Lisa played a key role in achieving compliance to the GDPR by advising the company regarding data protection obligations and creating a data protection strategy. After obtaining evidence of the existing data protection policy, Lisa proposed to adapt the policy to specific requirements of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of departments. As the DPO, she had access to several departments, including HR and Accounting Department. This assured the organization that there was a continuous cooperation between them. The activities of some departments within COR Bank are closely related to data protection. Therefore, considering their expertise, Lisa was advised from the top management to take orders from the heads of those departments when taking decisions related to their field. Based on this scenario, answer the following question:
Question:
According to scenario 3,Tibko stores archived data on behalf of COR Bank. This means that Tibko is a:
A. Data processor, since they store COR Bank's data based on the purpose and conditions defined by COR Bank.
B. Joint controller with COR Bank, since they archive COR Bank's data and take technical decisions regarding data protection.
C. Data controller, since they control some of the data from the application processes of COR Bank.
D. Independent controller, since Tibko handles data security and storage.
正解：A
解説: (Topexam メンバーにのみ表示されます)

質問 4：
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 question:
How could MA store prevent the SQL attack described in scenario 8?
A. Using security measures that support data protection at the database level, such as authorized queries
B. Using cryptographic protocols such as TLS as encryption mechanisms instead of a public key encryption
C. Processing only the data they actually need to achieve processing purposes in database and application servers
正解：A
解説: (Topexam メンバーにのみ表示されます)

質問 5：
Question:
Which of the following options is theDPO's responsibilitywhen processing personal datarelated to criminal convictionsis carried out by anofficial authority?
A. Assessingthe necessity of knowing a data subject's identity.
B. Determiningthe location where sensitive data may be processed.
C. Ensuringcompliance with any legal requirementsof Member States.
D. Approvingall security measures for processingthis data.
正解：C
解説: (Topexam メンバーにのみ表示されます)

質問 6：
Scenario3:
COR Bank is an international banking group that operates in 31 countries. It was formed as the merger of two well-known investment banks in Germany. Their two main fields of business are retail and investment banking. COR Bank provides innovative solutions for services such as payments, cash management, savings, protection insurance, and real-estate services. COR Bank has a large number of clients and transactions.
Therefore, they process large information, including clients' personal data. Some of the data from the application processes of COR Bank, including archived data, is operated by Tibko, an IT services company located in Canada. To ensure compliance with the GDPR, COR Bank and Tibko have reached a data processing agreement Based on the agreement, the purpose and conditions of data processing are determined by COR Bank. However, Tibko is allowed to make technical decisions for storing the data based on its own expertise. COR Bank aims to remain a trustworthy bank and a long-term partner for its clients. Therefore, they devote special attention to legal compliance. They started the implementation process of a GDPR compliance program in 2018. The first step was to analyze the existing resources and procedures. Lisa was appointed as the data protection officer (DPO). Being the information security manager of COR Bank for many years, Lisa had knowledge of the organization's core activities. She was previously involved in most of the processes related to information systems management and data protection. Lisa played a key role in achieving compliance to the GDPR by advising the company regarding data protection obligations and creating a data protection strategy. After obtaining evidence of the existing data protection policy, Lisa proposed to adapt the policy to specific requirements of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of departments. As the DPO, she had access to several departments,including HR and Accounting Department. This assured the organization that there was a continuous cooperation between them. The activities of some departments within COR Bank are closely related to data protection. Therefore, considering their expertise, Lisa was advised from the top management to take orders from the heads of those departments when taking decisions related to their field. Based on this scenario, answer the following question:
Question:
According to scenario 3,Lisa was appointed as the Data Protection Officer (DPO)of COR Bank. Is this action in compliance with GDPR?
A. No, Lisa cannot be appointed as a DPO because she was already an information security officer.
B. No, an external DPO must be contracted when personal data is collected or processed by an organization that is not established in the European Union.
C. Yes, the DPO may be a staff member of the controller or processor or fulfill the tasks based on a service contract.
D. Yes, the DPO must be a staff member of the controller or processor in all cases when processing includes special categories of data.
正解：C
解説: (Topexam メンバーにのみ表示されます)

質問 7：
Scenario5:
Recpond is a German employment recruiting company. Their services are delivered globally and include consulting and staffing solutions. In the beginning. Recpond provided its services through an office in Germany. Today, they have grown to become one of the largest recruiting agencies, providing employment to more than 500,000 people around the world. Recpond receives most applications through its website. Job searchers are required to provide the job title and location. Then, a list of job opportunities is provided. When a job position is selected, candidates are required to provide their contact details and professional work experience records. During the process, they are informed that the information will be used only for the purposes and period determined by Recpond. Recpond's experts analyze candidates' profiles and applications and choose the candidates that are suitable for the job position. The list of the selected candidates is then delivered to Recpond's clients, who proceed with the recruitment process. Files of candidates that are not selected are stored in Recpond's databases, including the personal data of candidates who withdraw the consent on which the processing was based. When the GDPR came into force, the company was unprepared.
The top management appointed a DPO and consulted him for all data protection issues. The DPO, on the other hand, reported the progress of all data protection activities to the topmanagement. Considering the level of sensitivity of the personal data processed by Recpond, the DPO did not have direct access to the personal data of all clients, unless the top management deemed it necessary. The DPO planned the GDPR implementation by initially analyzing the applicable GDPR requirements. Recpond, on the other hand, initiated a risk assessment to understand the risks associated with processing operations. The risk assessment was conducted based on common risks that employment recruiting companies face. After analyzing different risk scenarios, the level of risk was determined and evaluated. The results were presented to the DPO, who then decided to analyze only the risks that have a greater impact on the company. The DPO concluded that the cost required for treating most of the identified risks was higher than simply accepting them. Based on this analysis, the DPO decided to accept the actual level of the identified risks. After reviewing policies and procedures of the company. Recpond established a new data protection policy. As proposed by the DPO, the information security policy was also updated. These changes were then communicated to all employees of Recpond.Based on this scenario, answer the following question:
Question:
Which statement regarding thematerial scope of the GDPRisincorrect?
A. The GDPR applies to theprocessing of personal datain the course of an activity thatfalls outside the scope of Union law.
B. The GDPR applies to theprocessing of personal datawholly or partly byautomated means.
C. The GDPR does not apply to theprocessing of personal databyMember Stateswhen carrying out activitiesthat fall within the scope of the Treaty on European Union (TEU).
D. The GDPR applies to theprocessing of personal databy a company established in the EEA, even if the data subjects are located outside the EEA.
正解：A
解説: (Topexam メンバーにのみ表示されます)