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Please use the following to answer the next question:
You have just been hired by a toy manufacturer based in Hong Kong. The company sells a broad range of dolls, action figures and plush toys that can be found internationally in a wide variety of retail stores. Although the manufacturer has no offices outside Hong Kong and in fact does not employ any staff outside Hong Kong, it has entered into a number of local distribution contracts. The toys produced by the company can be found in all popular toy stores throughout Europe, the United States, Canada and Asia. A large portion of the company’s revenue is due to international sales.
The company now wishes to launch a new range of connected toys, ones that can talk and interact with children. The CEO of the company is touting these toys as the next big thing, due to the increased possibilities offered: The figures can answer children’s Questions: on various subjects, such as mathematical calculations or the weather. Each figure is equipped with a microphone and speaker and can connect to any smartphone or tablet via Bluetooth. Any mobile device within a 10-meter radius can connect to the toys via Bluetooth as well.
The figures can also be associated with other figures (from the same manufacturer) and interact with each other for an enhanced play experience.
When a child asks the toy a question, the request is sent to the cloud for analysis, and the answer is generated on cloud servers and sent back to the figure. The answer is given through the figure’s integrated speakers, making it appear as though that the toy is actually responding to the child’s question. The packaging of the toy does not provide technical details on how this works, nor does it mention that this feature requires an internet connection. The necessary data processing for this has been outsourced to a data center located in South Africa. However, your company has not yet revised its consumer-facing privacy policy to indicate this.
In parallel, the company is planning to introduce a new range of game systems through which consumers can play the characters they acquire in the course of playing the game. The system will come bundled with a portal that includes a Near-Field Communications (NFC) reader. This device will read an RFID tag in the action figure, making the figure come to life onscreen. Each character has its own stock features and abilities, but it is also possible to earn additional ones by accomplishing game goals. The only information stored in the tag relates to the figures’ abilities. It is easy to switch characters during the game, and it is possible to bring the figure to locations outside of the home and have the character’s abilities remain intact.
What presents the BIGGEST potential privacy issue with the company’s practices?

  • A. The RFID tag in the action figures has the potential for misuse because of the toy’s evolving capabilities
  • B. The NFC portal can read any data stored in the action figures
  • C. The cloud service provider is in a country that has not been deemed adequate
  • D. The information about the data processing involved has not been specified

Answer: D


Please use the following to answer the next QUESTION:
Matt went into his son’s bedroom one evening and found him stretched out on his bed typing on his laptop. “Doing your network?” Matt asked hopefully.
“No,” the boy said. “I’m filling out a survey.”
Matt looked over his son’s shoulder at his computer screen. “What kind of survey?” “It’s asking Questions about my opinions.”
“Let me see,” Matt said, and began reading the list of Questions that his son had already answered. “It’s asking your opinions about the government and citizenship. That’s a little odd. You’re only ten.” Matt wondered how the web link to the survey had ended up in his son’s email inbox. Thinking the message might have been sent to his son by mistake he opened it and read it. It had come from an entity called the Leadership Project, and the content and the graphics indicated that it was intended for children. As Matt read further he learned that kids who took the survey were automatically registered in a contest to win the first book in a series about famous leaders.
To Matt, this clearly seemed like a marketing ploy to solicit goods and services to children. He asked his son if he had been prompted to give information about himself in order to take the survey. His son told him he had been asked to give his name, address, telephone number, and date of birth, and to answer Questions about his favorite games and toys.
Matt was concerned. He doubted if it was legal for the marketer to collect information from his son in the way that it was. Then he noticed several other commercial emails from marketers advertising products for children in his son’s inbox, and he decided it was time to report the incident to the proper authorities.
Based on the incident, the FTC’s enforcement actions against the marketer would most likely include what violation?

  • A. Collecting information from a child under the age of thirteen.
  • B. Intruding upon the privacy of a family with young children.
  • C. Disregarding the privacy policy of the children’s marketing industry.
  • D. Failing to notify of a breach of children’s private information.

Answer: C


The GDPR requires controllers to supply data subjects with detailed information about the processing of their data. Where a controller obtains data directly from data subjects, which of the following items of information does NOT legally have to be supplied?

  • A. The right to lodge a complaint with a supervisory authority.
  • B. The categories of personal data concerned.
  • C. The recipients or categories of recipients.
  • D. The rights of access, erasure, restriction, and portability.

Answer: B


In which of the following cases, cited as an example by a WP29 guidance, would conducting a single data protection impact assessment to address multiple processing operations be allowed?

  • A. A railway operator who plans to evaluate the same video surveillance in all the train stations of his company.
  • B. A medical organization that wants to begin genetic testing to support earlier research for which they have performed a DPIA.
  • C. A marketing team that wants to collect mailing addresses of customers for whom they already have email addresses.
  • D. A data controller who plans to use a new technology product that has already undergone a DPIA by the product’s provider.

Answer: A



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