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Which control is NOT included in the requirements established by the Monetary Authority of Singapore (MAS) for financial institutions in order to deter money-laundering and financial aid to terrorism (AML/CFT)?

A.

Identifying and knowing customers.

B.

Sharing personal information with the PDPC.

C.

Conducting regular reviews of customer accounts.

D.

Monitoring and reporting suspicious financial transactions.

All of the following are guidelines the PDPC gives about anonymised data EXCEPT?

A.

Anonymised data is not personal data.

B.

Any data that has been anonymised bears the same risks for re-identification.

C.

Data that has been anonymised satisfies the "cease to retain" requirement of Section 25.

D.

Organizations should consider the risk of re-identification if it intends to publish or disclose anonymised data.

In Hong Kong's revised Breach Guidance Note of 2015, what course of action did the Commissioner recommend that companies take immediately after experiencing a breach?

A.

Proceed under the assumption that the breach is a threat to personal safety.

B.

Enlist the aid of law enforcement to determine the cause of the breach.

C.

Quickly issue a notification to the data subjects affected by the breach.

D.

Immediately gather essential information in relation to the breach.

Hong Kong's Personal Data (Privacy) Ordinance (PDPO) was primarily inspired by which of the following?

A.

Asia's APEC Privacy Framework.

B.

Macau's Personal Data Protection Act.

C.

South Korea's Public Agency Data Protection Act.

D.

Europe's Data Protection Directive (Directive 95/46/EC).

SCENARIO – Please use the following to answer the next QUESTION:

Fitness For Everyone ("FFE") is a gym on Hong Kong Island that is affiliated with a network of gyms throughout Southeast Asia. When prospective members of the gym stop in, call in or submit an inquiry online, they are invited for a free trial session. At first, the gym asks prospective clients only for basic information: a full name, contact number, age and their Hong Kong ID number, so that FFE's senior trainer Kelvin can reach them to arrange their first appointment.

One day, a potential customer named Stephen took a tour of the gym with Kelvin and then decided to join FFE for six months. Kelvin pulled out a registration form and explained FFE's policies, placing a circle next to the part that read "FEE and affiliated third parties" may market new products and services using the contact information provided on the form to Stephen "for the duration of his membership." Stephen asked if he could opt-out of the marketing communications. Kelvin shrugged and said that it was a standard part of the contract and that most gyms have it, but that even so Kelvin's manager wanted the item circled on all forms. Stephen agreed, signed the registration form at the bottom of the page, and provided his credit card details for a monthly gym fee. He also exchanged instant messenger/cell details with Kelvin so that they could communicate about personal training sessions scheduled to start the following week.

After attending the gym consistently for six months, Stephen's employer transferred him to another part of the Island, so he did not renew his FFE membership.

One year later, Stephen started to receive numerous text messages each day from unknown numbers, most marketing gym or weight loss products.

Suspecting that FFE shared his information widely, he contacted his old FFE branch and asked reception if they still had his information on file. They did, but offered to delete it if he wished. He was told FFE's process to purge his information from all the affiliated systems might take 8 to 12 weeks. FFE also informed him that Kelvin was no longer employed by FFE and had recently started working for a competitor. FFE believed that Kelvin may have shared the mobile contact details of his clients with the new gym, and apologized for this inconvenience.

Which of the following types of text messages are permissible, regardless of Stephen's withdrawal of consent?

A.

From the FFE retention department, offering a special discount for reactivating membership.

B.

From health care services provided by Hong Kong's Hospital Authority or Department of Health.

C.

From an FFE affiliate that provides a mechanism to opt out of further communications by reply-texting "OO."

D.

From an FFE affiliate in the region Stephen was transferred to, offering services similar to those he purchased previously.

Which Indian institution is vested with powers under the Credit Information Companies (Regulation) Act of 2005?

A.

The Reserve Bank of India.

B.

The National Housing Bank.

C.

The Oriental Bank of Commerce.

D.

The Securities and Exchange Board of India.

In India, the obligation to appoint a Grievance Officer applies ONLY to companies that?

A.

Deal with sensitive personal data.

B.

Conduct cross-border data transfers.

C.

Are considered part of the public sector.

D.

Lack alternate enforcement mechanisms.

SCENARIO – Please use the following to answer the next QUESTION:

Bharat Medicals is an established retail chain selling medical goods, with a presence in a number of cities throughout India. Their strategic partnership with major hospitals in these cities helped them capture an impressive market share over the years. However, with lifestyle and demographic shifts in India, the company saw a huge opportunity in door-to-door delivery of essential medical products. The need for such a service was confirmed by an independent consumer survey the firm conducted recently.

The company has launched their e-commerce platform in three metro cities, and plans to expand to the rest of the country in the future. Consumers need to register on the company website before they can make purchases. They are required to enter details such as name, age, address, telephone number, sex, date of birth and nationality – information that is stored on the company's servers. (Consumers also have the option of keeping their credit card number on file, so that it does not have to be entered every time they make payment.) If ordered items require a prescription, that authorization needs to be uploaded as well. The privacy notice explicitly requires that the consumer confirm that he or she is either the patient or has consent of the patient for uploading the health information. After creating a unique user ID and password, the consumer's registration will be confirmed through a text message sent to their listed mobile number.

To remain focused on their core business, Bharat outsourced the packaging, product dispatch and delivery activities to a third party firm, Maurya Logistics Ltd., with which it has a contractual agreement. It shares with Maurya Logistics the consumer name, address and other product-related details at the time of every purchase.

If consumers underwent medical treatment at one of the partner hospitals and consented to having their data transferred, their order requirement will be sent to their Bharat Medicals account directly, thereby doing away with the need to manually place an order for the medications.

Bharat Medicals takes regulatory compliance seriously; to ensure data privacy, it displays a privacy notice at the time of registration, and includes all the information that it collects. At this stage of their business, the company plans to store consumer information indefinitely, since the percentage of repeat customers and the frequency of orders per customer is still uncertain.

When collecting personal data, Bharat Medicals does NOT need to inform the consumer of what?

A.

The recipients of the collected data.

B.

The name of the body collecting the data.

C.

The type of safeguards protecting the data.

D.

The options the subject has to access his data.

Which of the following does Singapore's PDPC NOT have the power to do?

A.

Order an organization to stop collecting personal data.

B.

Order an organization to destroy collected personal data.

C.

Order an organization to award compensation to a complainant.

D.

Order an organization to pay a financial penalty to the government.

Under the PDPO, what are Hong Kong companies that make use of personal data required to do?

A.

Appoint an official compliance officer.

B.

Register with the appropriate data authority.

C.

Honor all data subject requests for correcting personal information.

D.

Provide contact information of persons handling data access requests.