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SCENARIO
Tom looked forward to starting his new position with a U.S —based automobile leasing company (New Company), now operating in 32 states. New Company was recently formed through the merger of two prominent players, one from the eastern region (East Company) and one from the western region (West Company). Tom, a Certified Information Privacy Technologist (CIPT), is New Company's first Information Privacy and Security Officer. He met today with Dick from East Company, and Harry, from West Company. Dick and Harry are veteran senior information privacy and security professionals at their respective companies, and continue to lead the east and west divisions of New Company. The purpose of the meeting was to conduct a SWOT (strengths/weaknesses/opportunities/threats) analysis for New Company. Their SWOT analysis conclusions are summarized below.
Dick was enthusiastic about an opportunity for the New Company to reduce costs and increase computing power and flexibility through cloud services. East Company had been contemplating moving to the cloud, but West Company already had a vendor that was providing it with software-as-a-service (SaaS). Dick was looking forward to extending this service to the eastern region. Harry noted that this was a threat as well, because West Company had to rely on the third party to protect its data.
Tom mentioned that neither of the legacy companies had sufficient data storage space to meet the projected growth of New Company, which he saw as a weakness. Tom stated that one of the team's first projects would be to construct a consolidated New Company data warehouse. Tom would personally lead this project and would be held accountable if information was modified during transmission to or during storage in the new data warehouse.
Tom, Dick and Harry agreed that employee network access could be considered both a strength and a weakness. East Company and West Company had strong performance records in this regard; both had robust network access controls that were working as designed. However, during a projected year-long transition period, New Company employees would need to be able to connect to a New Company network while retaining access to the East Company and West Company networks.
When employees are working remotely, they usually connect to a Wi-Fi network. What should Harry advise for maintaining company security in this situation?
What term describes two re-identifiable data sets that both come from the same unidentified individual?
Which of the following is the best method to minimize tracking through the use of cookies?
Which is likely to reduce the types of access controls needed within an organization?
SCENARIO
You have just been hired by Ancillary.com, a seller of accessories for everything under the sun, including waterproof stickers for pool floats and decorative bands and cases for sunglasses. The company sells cell phone cases, e-cigarette cases, wine spouts, hanging air fresheners for homes and automobiles, book ends, kitchen implements, visors and shields for computer screens, passport holders, gardening tools and lawn ornaments, and catalogs full of health and beauty products. The list seems endless. As the CEO likes to say, Ancillary offers, without doubt, the widest assortment of low-price consumer products from a single company anywhere.
Ancillary's operations are similarly diverse. The company originated with a team of sales consultants selling home and beauty products at small parties in the homes of customers, and this base business is still thriving. However, the company now sells online through retail sites designated for industries and demographics, sites such as “My Cool Ride" for automobile-related products or “Zoomer” for gear aimed toward young adults. The company organization includes a plethora of divisions, units and outrigger operations, as Ancillary has been built along a decentered model rewarding individual initiative and flexibility, while also acquiring key assets. The retail sites seem to all function differently, and you wonder about their compliance with regulations and industry standards. Providing tech support to these sites is also a challenge, partly due to a variety of logins and authentication protocols.
You have been asked to lead three important new projects at Ancillary:
The first is the personal data management and security component of a multi-faceted initiative to unify the company’s culture. For this project, you are considering using a series of third- party servers to provide company data and approved applications to employees.
The second project involves providing point of sales technology for the home sales force, allowing them to move beyond paper checks and manual credit card imprinting.
Finally, you are charged with developing privacy protections for a single web store housing all the company’s product lines as well as products from affiliates. This new omnibus site will be known, aptly, as “Under the Sun.” The Director of Marketing wants the site not only to sell Ancillary’s products, but to link to additional products from other retailers through paid advertisements. You need to brief the executive team of security concerns posed by this approach.
Which should be used to allow the home sales force to accept payments using smartphones?
An organization is launching a smart watch which, in addition to alerts, will notify the the wearer of incoming calls allowing them to answer on the device. This convenience also comes with privacy concerns and is an example of?
What is typically NOT performed by sophisticated Access Management (AM) techniques?
SCENARIO
Carol was a U.S.-based glassmaker who sold her work at art festivals. She kept things simple by only accepting cash and personal checks.
As business grew, Carol couldn't keep up with demand, and traveling to festivals became burdensome. Carol opened a small boutique and hired Sam to run it while she worked in the studio. Sam was a natural salesperson, and business doubled. Carol told Sam, “I don't know what you are doing, but keep doing it!"
But months later, the gift shop was in chaos. Carol realized that Sam needed help so she hired Jane, who had business expertise and could handle the back-office tasks. Sam would continue to focus on sales. Carol gave Jane a few weeks to get acquainted with the artisan craft business, and then scheduled a meeting for the three of them to discuss Jane's first impressions.
At the meeting, Carol could not wait to hear Jane's thoughts, but she was unprepared for what Jane had to say. “Carol, I know that he doesn't realize it, but some of Sam’s efforts to increase sales have put you in a vulnerable position. You are not protecting customers’ personal information like you should.”
Sam said, “I am protecting our information. I keep it in the safe with our bank deposit. It's only a list of customers’ names, addresses and phone numbers that I get from their checks before I deposit them. I contact them when you finish a piece that I think they would like. That's the only information I have! The only other thing I do is post photos and information about your work on the photo sharing site that I use with family and friends. I provide my email address and people send me their information if they want to see more of your work. Posting online really helps sales, Carol. In fact, the only complaint I hear is about having to come into the shop to make a purchase.”
Carol replied, “Jane, that doesn’t sound so bad. Could you just fix things and help us to post even more online?"
‘I can," said Jane. “But it's not quite that simple. I need to set up a new program to make sure that we follow the best practices in data management. And I am concerned for our customers. They should be able to manage how we use their personal information. We also should develop a social media strategy.”
Sam and Jane worked hard during the following year. One of the decisions they made was to contract with an outside vendor to manage online sales. At the end of the year, Carol shared some exciting news. “Sam and Jane, you have done such a great job that one of the biggest names in the glass business wants to buy us out! And Jane, they want to talk to you about merging all of our customer and vendor information with theirs beforehand."
What type of principles would be the best guide for Jane's ideas regarding a new data management program?
SCENARIO
Looking back at your first two years as the Director of Personal Information Protection and Compliance for the St. Anne’s Regional Medical Center in Thorn Bay, Ontario, Canada, you see a parade of accomplishments, from developing state-of-the-art simulation based training for employees on privacy protection to establishing an interactive medical records system that is accessible by patients as well as by the medical personnel. Now, however, a question you have put off looms large: how do we manage all the data-not only records produced recently, but those still on-hand from years ago? A data flow diagram generated last year shows multiple servers, databases, and work stations, many of which hold files that have not yet been incorporated into the new records system. While most of this data is encrypted, its persistence may pose security and compliance concerns. The situation is further complicated by several long-term studies being conducted by the medical staff using patient information. Having recently reviewed the major Canadian privacy regulations, you want to make certain that the medical center is observing them.
You recall a recent visit to the Records Storage Section in the basement of the old hospital next to the modern facility, where you noticed paper records sitting in crates labeled by years, medical condition or alphabetically by patient name, while others were in undifferentiated bundles on shelves and on the floor. On the back shelves of the section sat data tapes and old hard drives that were often unlabeled but appeared to be years old. On your way out of the records storage section, you noticed a man leaving whom you did not recognize. He carried a batch of folders under his arm, apparently records he had removed from storage.
You quickly realize that you need a plan of action on the maintenance, secure storage and disposal of data.
Which cryptographic standard would be most appropriate for protecting patient credit card information in the records system at St. Anne’s Regional Medical Center?
An individual drives to the grocery store for dinner. When she arrives at the store, she receives several unsolicited notifications on
her phone about discounts on items at the grocery store she is about to shop at. Which type of privacy problem does the represent?
A developer is designing a new system that allows an organization's helpdesk to remotely connect into the device of the individual to provide support Which of the following will be a privacy technologist's primary concern"?
A company configures their information system to have the following capabilities:
Allow for selective disclosure of attributes to certain parties, but not to others.
Permit the sharing of attribute references instead of attribute values - such as “I am over 21” instead of birthday date.
Allow for information to be altered or deleted as needed.
These capabilities help to achieve which privacy engineering objective?
SCENARIO
Please use the following to answer the next question:
Chuck, a compliance auditor for a consulting firm focusing on healthcare clients, was required to travel to the client’s office to perform an onsite review of the client’s operations. He rented a car from Finley Motors upon arrival at the airport as so he could commute to and from the client’s office. The car rental agreement was electronically signed by Chuck and included his name, address, driver’s license, make/model of the car, billing rate, and additional details describing the rental transaction. On the second night, Chuck was caught by a red light camera not stopping at an intersection on his way to dinner. Chuck returned the car back to the car rental agency at the end week without mentioning the infraction and Finley Motors emailed a copy of the final receipt to the address on file.
Local law enforcement later reviewed the red light camera footage. As Finley Motors is the registered owner of the car, a notice was sent to them indicating the infraction and fine incurred. This notice included the license plate number, occurrence date and time, a photograph of the driver, and a web portal link to a video clip of the violation for further review. Finley Motors, however, was not responsible for the violation as they were not driving the car at the time and transferred the incident to AMP Payment Resources for further review. AMP Payment Resources identified Chuck as the driver based on the rental agreement he signed when picking up the car and then contacted Chuck directly through a written letter regarding the infraction to collect the fine.
After reviewing the incident through the AMP Payment Resources’ web portal, Chuck paid the fine using his personal credit card. Two weeks later, Finley Motors sent Chuck an email promotion offering 10% off a future rental.
What is the strongest method for authenticating Chuck’s identity prior to allowing access to his violation information through the AMP Payment Resources web portal?
An organization is using new technologies that will target and process personal data of EU customers. In which of the following circumstances would a privacy technologist need to support a data protection impact assessment (DPIA)?
What is a mistake organizations make when establishing privacy settings during the development of applications?
What risk is mitigated when routing meeting video traffic through a company’s application servers rather than sending the video traffic directly from one user to another?
SCENARIO
Looking back at your first two years as the Director of Personal Information Protection and Compliance for the Berry Country Regional Medical Center in Thorn Bay, Ontario, Canada, you see a parade of accomplishments, from developing state-of-the-art simulation based training for employees on privacy protection to establishing an interactive medical records system that is accessible by patients as well as by the medical personnel. Now, however, a question you have put off looms large: how do we manage all the data-not only records produced recently, but those still on hand from years ago? A data flow diagram generated last year shows multiple servers, databases, and work stations, many of which hold files that have not yet been incorporated into the new records system. While most of this data is encrypted, its persistence may pose security and compliance concerns. The situation is further complicated by several long-term studies being conducted by the medical staff using patient information. Having recently reviewed the major Canadian privacy regulations, you want to make certain that the medical center is observing them.
You also recall a recent visit to the Records Storage Section, often termed “The Dungeon” in the basement of the old hospital next to the modern facility, where you noticed a multitude of paper records. Some of these were in crates marked by years, medical condition or alphabetically by patient name, while others were in undifferentiated bundles on shelves and on the floor. The back shelves of the section housed data tapes and old hard drives that were often unlabeled but appeared to be years old. On your way out of the dungeon, you noticed just ahead of you a small man in a lab coat who you did not recognize. He carried a batch of folders under his arm, apparently records he had removed from storage.
Which cryptographic standard would be most appropriate for protecting patient credit card information in the records system?
What is the main privacy threat posed by Radio Frequency Identification (RFID)?
SCENARIO
Looking back at your first two years as the Director of Personal Information Protection and Compliance for the Berry Country Regional Medical Center in Thorn Bay, Ontario, Canada, you see a parade of accomplishments, from developing state-of-the-art simulation based training for employees on privacy protection to establishing an interactive medical records system that is accessible by patients as well as by the medical personnel. Now, however, a question you have put off looms large: how do we manage all the data-not only records produced recently, but those still on hand from years ago? A data flow diagram generated last year shows multiple servers, databases, and work stations, many of which hold files that have not yet been incorporated into the new records system. While most of this data is encrypted, its persistence may pose security and compliance concerns. The situation is further complicated by several long-term studies being conducted by the medical staff using patient information. Having recently reviewed the major Canadian privacy regulations, you want to make certain that the medical center is observing them.
You also recall a recent visit to the Records Storage Section, often termed “The Dungeon” in the basement of the old hospital next to the modern facility, where you noticed a multitude of paper records. Some of these were in crates marked by years, medical condition or alphabetically by patient name, while others were in undifferentiated bundles on shelves and on the floor. The back shelves of the section housed data tapes and old hard drives that were often unlabeled but appeared to be years old. On your way out of the dungeon, you noticed just ahead of you a small man in a lab coat who you did not recognize. He carried a batch of folders under his arm, apparently records he had removed from storage.
Which regulation most likely applies to the data stored by Berry Country Regional Medical Center?
An organization is considering launching enhancements to improve security and authentication mechanisms in their products. To better identify the user and reduce friction from the authentication process, they plan to track physical attributes of an individual. A privacy technologist assessing privacy implications would be most interested in which of the following?
Which of the following is NOT a step in the methodology of a privacy risk framework?
Which of the following would be the most appropriate solution for preventing privacy violations related to information exposure through an error message?
SCENARIO
Tom looked forward to starting his new position with a U.S —based automobile leasing company (New Company), now operating in 32 states. New Company was recently formed through the merger of two prominent players, one from the eastern region (East Company) and one from the western region (West Company). Tom, a Certified Information Privacy Technologist (CIPT), is New Company's first Information Privacy and Security Officer. He met today with Dick from East Company, and Harry, from West Company. Dick and Harry are veteran senior information privacy and security professionals at their respective companies, and continue to lead the east and west divisions of New Company. The purpose of the meeting was to conduct a SWOT (strengths/weaknesses/opportunities/threats) analysis for New Company. Their SWOT analysis conclusions are summarized below.
Dick was enthusiastic about an opportunity for the New Company to reduce costs and increase computing power and flexibility through cloud services. East Company had been contemplating moving to the cloud, but West Company already had a vendor that was providing it with software-as-a-service (SaaS). Dick was looking forward to extending this service to the eastern region. Harry noted that this was a threat as well, because West Company had to rely on the third party to protect its data.
Tom mentioned that neither of the legacy companies had sufficient data storage space to meet the projected growth of New Company, which he saw as a weakness. Tom stated that one of the team's first projects would be to construct a consolidated New Company data warehouse. Tom would personally lead this project and would be held accountable if information was modified during transmission to or during storage in the new data warehouse.
Tom, Dick and Harry agreed that employee network access could be considered both a strength and a weakness. East Company and West Company had strong performance records in this regard; both had robust network access controls that were working as designed. However, during a projected year-long transition period, New Company employees would need to be able to connect to a New Company network while retaining access to the East Company and West Company networks.
Which statement is correct about addressing New Company stakeholders’ expectations for privacy?
SCENARIO
Please use the following to answer the next question:
Light Blue Health (LBH) is a healthcare technology company developing a new web and mobile application that collects personal health information from electronic patient health records. The application will use machine learning to recommend potential medical treatments and medications based on information collected from anonymized electronic health records. Patient users may also share health data collected from other mobile apps with the LBH app.
The application requires consent from the patient before importing electronic health records into the application and sharing it with their authorized physicians or healthcare provider. The patient can then review and share the recommended treatments with their physicians securely through the app. The patient user may also share location data and upload photos in the app. The patient user may also share location data and upload photos in the app for a healthcare provider to review along with the health record. The patient may also delegate access to the app.
LBH’s privacy team meets with the Application development and Security teams, as well as key business stakeholders on a periodic basis. LBH also implements Privacy by Design (PbD) into the application development process.
The Privacy Team is conducting a Privacy Impact Assessment (PIA) to evaluate privacy risks during development of the application. The team must assess whether the application is collecting descriptive, demographic or any other user related data from the electronic health records that are not needed for the purposes of the application. The team is also reviewing whether the application may collect additional personal data for purposes for which the user did not provide consent.
Regarding the app, which action is an example of a decisional interference violation?
Implementation of privacy controls for compliance with the requirements of the Children’s Online Privacy Protection Act (COPPA) is necessary for all the following situations EXCEPT?
Which of the following is a vulnerability of a sensitive biometrics authentication system?
What is the main reason the Do Not Track (DNT) header is not acknowledged by more companies?
You are a wine collector who uses the web to do research about your hobby. You navigate to a news site and an ad for wine pops up. What kind of advertising is this?
Which of the following is most important to provide to the data subject before the collection phase of the data lifecycle?
SCENARIO
Wesley Energy has finally made its move, acquiring the venerable oil and gas exploration firm Lancelot from its long-time owner David Wilson. As a member of the transition team, you have come to realize that Wilson's quirky nature affected even Lancelot's data practices, which are maddeningly inconsistent. “The old man hired and fired IT people like he was changing his necktie,” one of Wilson’s seasoned lieutenants tells you, as you identify the traces of initiatives left half complete.
For instance, while some proprietary data and personal information on clients and employees is encrypted, other sensitive information, including health information from surveillance testing of employees for toxic exposures, remains unencrypted, particularly when included within longer records with less-sensitive data. You also find that data is scattered across applications, servers and facilities in a manner that at first glance seems almost random.
Among your preliminary findings of the condition of data at Lancelot are the following:
Cloud technology is supplied by vendors around the world, including firms that you have not heard of. You are told by a former Lancelot employee that these vendors operate with divergent security requirements and protocols.
The company’s proprietary recovery process for shale oil is stored on servers among a variety of less-sensitive information that can be accessed not only by scientists, but by personnel of all types at most company locations.
DES is the strongest encryption algorithm currently used for any file.
Several company facilities lack physical security controls, beyond visitor check-in, which familiar vendors often bypass.
Fixing all of this will take work, but first you need to grasp the scope of the mess and formulate a plan of action to address it.
Which is true regarding the type of encryption Lancelot uses?
it Is Important for a privacy technologist to understand dark patterns In order to reduce the risk of which of the following?
Which privacy engineering objective proposed by the US National Institute of Science and Technology (NIST) decreases privacy risk by ensuring that connections between individuals and their personal data are reduced?
What is the main issue pertaining to data protection with the use of 'deep fakes'?
Ivan is a nurse for a home healthcare service provider in the US. The company has implemented a mobile application which Ivan uses to record a patient's vital statistics and access a patient's health care records during home visits. During one visitj^van is unable to access the health care application to record the patient's vitals. He instead records the information on his mobile phone's note-taking application to enter the data in the health care application the next time it is accessible. What would be the best course of action by the IT department to ensure the data is protected on his device?
SCENARIO
WebTracker Limited is a cloud-based online marketing service located in London. Last year, WebTracker migrated its IT infrastructure to the cloud provider AmaZure, which provides SQL Databases and Artificial Intelligence services to WebTracker. The roles and responsibilities between the two companies have been formalized in a standard contract, which includes allocating the role of data controller to WebTracker.
The CEO of WebTracker, Mr. Bond, would like to assess the effectiveness of AmaZure's privacy controls, and he recently decided to hire you as an independent auditor. The scope of the engagement is limited only to the marketing services provided by WebTracker, you will not be evaluating any internal data processing activity, such as HR or Payroll.
This ad-hoc audit was triggered due to a future partnership between WebTracker and SmartHome — a partnership that will not require any data sharing. SmartHome is based in the USA, and most recently has dedicated substantial resources to developing smart refrigerators that can suggest the recommended daily calorie intake based on DNA information. This and other personal data is collected by WebTracker.
To get an idea of the scope of work involved, you have decided to start reviewing the company's documentation and interviewing key staff to understand potential privacy risks.
The results of this initial work include the following notes:
There are several typos in the current privacy notice of WebTracker, and you were not able to find the privacy notice for SmartHome.
You were unable to identify all the sub-processors working for SmartHome. No subcontractor is indicated in the cloud agreement with AmaZure, which is responsible for the support and maintenance of the cloud infrastructure.
There are data flows representing personal data being collected from the internal employees of WebTracker, including an interface from the HR system.
Part of the DNA data collected by WebTracker was from employees, as this was a prototype approved by the CEO of WebTracker.
All the WebTracker and SmartHome customers are based in USA and Canada.
Which of the following issues is most likely to require an investigation by the Chief Privacy Officer (CPO) of WebTracker?
To meet data protection and privacy legal requirements that may require personal data to be disposed of or deleted when no longer necessary for the use it was collected, what is the best privacy-enhancing solution a privacy technologist should recommend be implemented in application design to meet this requirement?
SCENARIO
Kyle is a new security compliance manager who will be responsible for coordinating and executing controls to ensure compliance with the company's information security policy and industry standards. Kyle is also new to the company, where collaboration is a core value. On his first day of new-hire orientation, Kyle's schedule included participating in meetings and observing work in the IT and compliance departments.
Kyle spent the morning in the IT department, where the CIO welcomed him and explained that her department was responsible for IT governance. The CIO and Kyle engaged in a conversation about the importance of identifying meaningful IT governance metrics. Following their conversation, the CIO introduced Kyle to Ted and Barney. Ted is implementing a plan to encrypt data at the transportation level of the organization's wireless network. Kyle would need to get up to speed on the project and suggest ways to monitor effectiveness once the implementation was complete. Barney explained that his short-term goals are to establish rules governing where data can be placed and to minimize the use of offline data storage.
Kyle spent the afternoon with Jill, a compliance specialist, and learned that she was exploring an initiative for a compliance program to follow self-regulatory privacy principles. Thanks to a recent internship, Kyle had some experience in this area and knew where Jill could find some support. Jill also shared results of the company’s privacy risk assessment, noting that the secondary use of personal information was considered a high risk.
By the end of the day, Kyle was very excited about his new job and his new company. In fact, he learned about an open position for someone with strong qualifications and experience with access privileges, project standards board approval processes, and application-level obligations, and couldn’t wait to recommend his friend Ben who would be perfect for the job.
Ted's implementation is most likely a response to what incident?
An organization is deciding between building a solution in-house versus purchasing a solution for a new customer facing application. When security threat are taken into consideration, a key advantage of purchasing a solution would be the availability of?
After committing to a Privacy by Design program, which activity should take place first?
SCENARIO
Clean-Q is a company that offers house-hold and office cleaning services. The company receives requests from consumers via their website and telephone, to book cleaning services. Based on the type and size of service, Clean-Q then contracts individuals that are registered on its resource database - currently managed in-house by Clean-Q IT Support. Because of Clean-Q's business model, resources are contracted as needed instead of permanently employed.
The table below indicates some of the personal information Clean-Q requires as part of its business operations:
Clean-Q has an internal employee base of about 30 people. A recent privacy compliance exercise has been conducted to align employee data management and human resource functions with applicable data protection regulation. Therefore, the Clean-Q permanent employee base is not included as part of this scenario.
With an increase in construction work and housing developments, Clean-Q has had an influx of requests for cleaning services. The demand has overwhelmed Clean-Q's traditional supply and demand system that has caused some overlapping bookings.
Ina business strategy session held by senior management recently, Clear-Q invited vendors to present potential solutions to their current operational issues. These vendors included Application developers and Cloud-Q’s solution providers, presenting their proposed solutions and platforms.
The Managing Director opted to initiate the process to integrate Clean-Q's operations with a cloud solution (LeadOps) that will provide the following solution one single online platform: A web interface that Clean-Q accesses for the purposes of resource and customer management. This would entail uploading resource and customer information.
A customer facing web interface that enables customers to register, manage and submit cleaning service requests online.
A resource facing web interface that enables resources to apply and manage their assigned jobs.
An online payment facility for customers to pay for services.
What is a key consideration for assessing external service providers like LeadOps, which will conduct personal information processing operations on Clean-Q's behalf?
Which Privacy by Design principle requires architects and operators to emphasize the interests of the individual by offering measures such as strong privacy defaults, appropriate
notice, and user-friendly options?
Which of the following activities would be considered the best method for an organization to achieve the privacy principle of data quality'?
An organization has recently experienced a data breach where large amounts of personal data were compromised. As part of a post-incident review, the privacy technologist wants to analyze available data to understand what vulnerabilities may have contributed to the incident occurring. He learns that a key vulnerability had been flagged by the system but that detective controls were not operating effectively. Which type of web application security risk does this finding most likely point to?
Which is NOT a suitable action to apply to data when the retention period ends?
Which of the following is NOT relevant to a user exercising their data portability rights?
Which of the following would be an example of an "objective" privacy harm to an individual?
What would be an example of an organization transferring the risks associated with a data breach?
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?
Combining multiple pieces of information about an individual to produce a whole that is greater than the sum of its parts is called?
TESTED 21 Nov 2024
