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Scenario:
An organization conducted anonline surveyto gather opinions onglobal warming. The survey collected personal data, includingage, nationality, gender, and city of residence.
Question:
What should be considered whenidentifying this processing activity?
Which statement below regarding the difference between anonymization and pseudonymization is correct?
Scenario:
Pinky, a retail company,received a requestfrom adata subjectto identify which purchasesthey had madeat differentphysical store locations. However,Pinky does not link purchase records to customer identities, since purchasesdo not require account creation.
Question:
Should Pinkyprocess additional informationfrom customers in order toidentify the data subjectas requested?
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 systemacross 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 DPIA. Appointing a DPO at that point was deemed unnecessary. However, the data processor’s suggestions regarding the CCTV installation were taken into account. Step 3: Risk Likelihood (Unlikely, Possible, Likely) Severity (Moderate, Severe, Critical) Overall risk (Low, Medium, High) There is a risk that the principle of lawfulness, fairness, and transparency will be compromised since individuals might not be aware of the CCTV location and its field of view. Likely Moderate Low There is a risk that the principle of integrity and confidentiality may be compromised in case the CCTV system is not monitored and controlled with adequate security measures. Possible Severe Medium There is a risk related to the right of individuals to be informed regarding the installation of CCTV cameras. Possible Moderate Low Step 4: Bus Spot will provide appropriate training to individuals that have access to the information generated by the CCTV system. In addition, it will ensure that the employees of the data processor are trained as well. In each entrance of the bus, a sign for the use of CCTV will be displayed. The sign will be visible and readable by all passengers. It will show other details such as the purpose of its use, the identity of Bus Spot, and its contact number in case there are any queries. Only two employees of Bus Spot will be authorized to access the CCTV system. They will continuously monitor it and report any unusual behavior of bus drivers or passengers to Bus Spot. The requests of individuals that are subject to a criminal activity for accessing the CCTV images will be evaluated only for a limited period of time. If the access is allowed, the CCTV images will be exported by the CCTV system to an appropriate file format. Bus Spot will use a file encryption software to encrypt data before transferring onto another file format. Step 5: Bus Spot's top management has evaluated the DPIA results for the processing of data through CCTV system. The actions suggested to address the identified risks have been approved and will be implemented based on best practices. This DPIA involves the analysis of the risks and impacts in only a group of buses located in the capital of Spain. Therefore, the DPIA will be reconducted for each of Bus Spot's buses in Spain before installing the CCTV system. Based on this scenario, answer the following question:
Question:
According to scenario 6, whichdata protection solutionhas Bus Spot used to reduce the risk related to theprinciple of lawfulness, fairness, and transparency?
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 DPIA. Appointing a DPO at that point was deemed unnecessary. However, the data processor’s suggestions regarding the CCTV installation were taken into account. Step 3: Risk Likelihood (Unlikely, Possible, Likely) Severity (Moderate, Severe, Critical) Overall risk (Low, Medium, High) There is a risk that the principle of lawfulness, fairness, and transparency will be compromised since individuals might not be aware of the CCTV location and its field of view. Likely Moderate Low There is a risk that the principle of integrity and confidentiality may be compromised in case the CCTV system is not monitored and controlled with adequate security measures. Possible Severe Medium There is a risk related to the right of individuals to be informed regarding the installation of CCTV cameras. Possible Moderate Low Step 4: Bus Spot will provide appropriate training to individuals that have access to the information generated by the CCTV system. In addition, it will ensure that the employees of the data processor are trained as well. In each entrance of the bus, a sign for the use of CCTV will be displayed. The sign will be visible and readable by all passengers. It will show other details such as the purpose of its use, the identity of Bus Spot, and its contact number in case there are any queries. Only two employees of Bus Spot will be authorized to access the CCTV system. They will continuously monitor it and report any unusual behavior of bus drivers or passengers to Bus Spot. The requests of individuals that are subject to a criminal activity for accessing the CCTV images will be evaluated only for a limited period of time. If the access is allowed, the CCTV images will be exported by the CCTV system to an appropriate file format. Bus Spot will use a file encryption software to encrypt data before transferring onto another file format. Step 5: Bus Spot's topmanagement has evaluated the DPIA results for the processing of data through CCTV system. The actions suggested to address the identified risks have been approved and will be implemented based on best practices. This DPIA involves the analysis of the risks and impacts in only a group of buses located in the capital of Spain. Therefore, the DPIA will be reconducted for each of Bus Spot's buses in Spain before installing the CCTV system. Based on this scenario, answer the following question:
Question:
Based on scenario 6, Bus Spot decidednot to appoint a DPOwhen conducting the DPIA.
Which option iscorrectregarding this situation?
Question:
According toArticle 82 of GDPR, when must aprocessor be held liablefordamage caused by processing?
Scenario 9:Soin is a French travel agency with the largest network of professional travel agents throughout Europe. They aim to create unique vacations for clients regardless of the destinations they seek. The company specializes in helping people find plane tickets, reservations at hotels, cruises, and other activities.
As any other industry, travel is no exception when it comes to GDPR compliance. Soin was directly affected by the enforcement of GDPR since its main activities require the collection and processing of customers’ data. Data collected by Soin includes customer's ID or passport details, financial and payment information, and contact information. This type of data is defined as personal by the GDPR; hence, Soin's data processing activities are built based on customer's consent.
At the beginning, as for many other companies, GDPR compliance was a complicated issue for Soin. However, the process was completed within a few months and later on the company appointed a DPO. Last year, the supervisory authority of France, requested the conduct of a data protection external audit in Soin without an early notice. To ensure GDPR compliance before an external audit was conducted, Soin organized an internal audit. The data protection internal audit was conducted by the DPO of the company. The audit was initiated by firstly confirming the accuracy of records related to all current Soin's data processing activities. The DPO considered that verifying compliance to Article 30 of GDPR would help in defining the data protection internal audit scope. The DPO noticed that not all processing activities of Soin were documented as required by the GDPR. For example, processing activities records of the company did not include a description of transfers of personal data to third countries. In addition, there was no clear description of categories of personal data processed by the company. Other areas that were audited included content of data protection policy, data retention guidelines, how sensitive data is stored, and security policies and practices. The DPO conducted interviews with some employees at different levels of the company. During the audit, the DPO came across some emails sent by Soin's clients claiming that they do not have access in their personal data stored by Soin. Soin's Customer Service Department answered the emails saying that, based on Soin's policies, a client cannot have access to personal data stored by the company. Based on the information gathered, the DPO concluded that there was a lack of employee awareness on the GDPR.
All these findings were documented in the audit report. Once the audit was completed, the DPO drafted action plans to resolve the nonconformities found. Firstly, the DPO created a new procedure which could ensure the right of access to clients. All employees were provided with GDPR compliance awareness sessions. Moreover, the DPO established a document which described the transfer of personal data to third countries and the applicability of safeguards when this transfer is done to an international organization.
Based on this scenario, answer the following question:
Can the DPO appointed by Soin carry out the data protection external audit requested by the supervisory authority?
Scenario:
BookStis anonline bookshopthat collectspersonal databefore selling its products.Sarah signed up for an account, providing hername, email, and password. To purchase a book, Sarah was required to provide hershipping address and payment information, which isneeded to calculate shipping costsandcomplete the transaction.
Question:
Does the company have alegal basisfor processing Sarah's 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 itscustomers 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:
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?
Scenario:
Amarketing companydiscovers that anunauthorized party accessed its customer database, exposing5,000 recordscontainingnames, email addresses, and phone numbers. The breach occurred due to amisconfigured server.
Question:
To comply withGDPR, whichinformation must the company includein itsnotification to the supervisory authority?
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:
Considering the GDPR's territorial scope and thedata processing agreementbetween COR Bank and Tibko, which of the following best describes Tibko's obligations under the GDPR?
Question:
Which of the following options is theDPO’s responsibilitywhen processing personal datarelated to criminal convictionsis carried out by anofficial authority?
When pseudonymization is used in a dataset, the data is divided into restricted access data and non-identifiable data. This restricted access data includes gender, occupation, and age, whereas the non-identifiable data includes only nationality. Is this correct?
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's compromised 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 preparedto handle such an attack.Based on this scenario, answer the following question:
Question:
Based on scenario 7, due to the attack, personal data ofEduCCS' clients(such as names, email addresses, and phone numbers) were unlawfully accessed.
According to GDPR,when must EduCCS inform its clientsabout this personal data breach?
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 DPIA. Appointing a DPO at that point was deemed unnecessary. However, the data processor’s suggestions regarding the CCTV installation were taken into account. Step 3: Risk Likelihood (Unlikely, Possible, Likely) Severity (Moderate, Severe, Critical) Overall risk (Low, Medium, High) There is a risk that the principle of lawfulness, fairness, and transparency will be compromised since individuals might not be aware of the CCTV location and its field of view. Likely Moderate Low There is a risk that the principle of integrity and confidentiality may be compromised in case the CCTV system is not monitored and controlled with adequate security measures. Possible Severe Medium There is a risk related to the right of individuals to be informed regarding the installation of CCTV cameras. Possible Moderate Low Step 4: Bus Spot will provide appropriate training to individuals that have access to the information generated by the CCTV system. In addition, it will ensure that the employees of the data processor are trained as well. In each entrance of the bus, a sign for the use of CCTV will bedisplayed. The sign will be visible and readable by all passengers. It will show other details such as the purpose of its use, the identity of Bus Spot, and its contact number in case there are any queries. Only two employees of Bus Spot will be authorized to access the CCTV system. They will continuously monitor it and report any unusual behavior of bus drivers or passengers to Bus Spot. The requests of individuals that are subject to a criminal activity for accessing the CCTV images will be evaluated only for a limited period of time. If the access is allowed, the CCTV images will be exported by the CCTV system to an appropriate file format. Bus Spot will use a file encryption software to encrypt data before transferring onto another file format. Step 5: Bus Spot's top management has evaluated the DPIA results for the processing of data through CCTV system. The actions suggested to address the identified risks have been approved and will be implemented based on best practices. This DPIA involves the analysis of the risks and impacts in only a group of buses located in the capital of Spain. Therefore, the DPIA will be reconducted for each of Bus Spot's buses in Spain before installing the CCTV system. Based on this scenario, answer the following question:
Question:
Is aDPIA necessaryfor Bus Spot?
Scenario:
A financial institution collectsbiometric data of its clients, such asface recognition, to support apayment authentication processthat they recently developed. The institution ensures thatdata subjects provide explicit consentfor the processing of theirbiometric datafor this specific purpose.
Question:
Based on this scenario, should theDPO advise the organization to conduct a DPIA (Data Protection Impact Assessment)?
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 top management. 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:
Based on scenario 5, theDPO reports directly to Recpond’s top management. Is this in alignment with GDPR requirements?
Scenario:
Aclinical research organizationcollects and processessensitive personal dataof individuals formedical research purposes. The data isencrypted and stored in a central database using a one-way hashing function (bcrypt). The organization conducted arisk assessmentto identify andmitigate risks.
Question:
Should aDPIA be conductedin this case?
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 canbenefit 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's compromised 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:
ShouldEduCCS document information related to the personal data breach, includingfacts, its impact, and the remedial action taken?
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. Step2: 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 DPIA. Appointing a DPO at that point was deemed unnecessary. However, the data processor’s suggestions regarding the CCTV installation were taken into account. Step 3: Risk Likelihood (Unlikely, Possible, Likely) Severity (Moderate, Severe, Critical) Overall risk (Low, Medium, High) There is a risk that the principle of lawfulness, fairness, and transparency will be compromised since individuals might not be aware of the CCTV location and its field of view. Likely Moderate Low There is a risk that the principle of integrity and confidentiality may be compromised in case the CCTV system is not monitored and controlled with adequate security measures. Possible Severe Medium There is a risk related to the right of individuals to be informed regarding the installation of CCTV cameras. Possible Moderate Low Step 4: Bus Spot will provide appropriate training to individuals that have access to the information generated by the CCTV system. In addition, it will ensure that the employees of the data processor are trained as well. In each entrance of the bus, a sign for the use of CCTV will be displayed. The sign will be visible and readable by all passengers. It will show other details such as the purpose of its use, the identity of Bus Spot, and its contact number in case there are any queries. Only two employees of Bus Spot will be authorized to access the CCTV system. They will continuously monitor it and report any unusual behavior of bus drivers or passengers to Bus Spot. The requests of individuals that are subject to a criminal activity for accessing the CCTV images will be evaluated only for a limited period of time. If the access is allowed, the CCTV images will be exported by the CCTV system to an appropriate file format. Bus Spot will use a file encryption software to encrypt data before transferring onto another file format. Step 5: Bus Spot's top management has evaluated the DPIA results for the processing of data through CCTV system. The actions suggested to address the identified risks have been approved and will be implemented based on best practices. This DPIA involves the analysis of the risks and impacts in only a group of buses located in the capital of Spain. Therefore, the DPIA will be reconducted for each of Bus Spot's buses in Spain before installing the CCTV system. Based on this scenario, answer the following question:
Question:
You are appointed as theDPO of Bus Spot.
What action would yousuggestwhen reviewing the results of theDPIApresented in scenario 6?
TESTED 02 May 2025