Which jurisdiction was the first to consider IP addresses to be personal information?

• A. The United States.
• B. The European Union.
• C. India.
• D. Hong Kong.

In addition to adhering to the data export principle of section 43A of India's IT Act 2000, data exporters in India must also follow principles of?

• A. Third party assessment.
• B. Mandatory registration.
• C. Privity of contract.
• D. Disclosure limitation.

SCENARIO - Please use the following to answer the next QUESTION:
Dracarys Inc. is a large multinational company with headquarters in Seattle, Washington, U.S.A.
Dracarys began as a small company making and selling women's clothing, but rapidly grew through its early innovative use of online platforms to sell its products. Dracarys is now one of the biggest names in the industry, and employs staff across the globe, and in Asia has employees located in both Singapore and Hong Kong.
Due to recent management restructuring they have decided, on the advice of external consultants, to open an office in India in order to centralize its call center as well as its internal human resource functions for the Asia region. Dracarys would like to centralize the following human resource functions in India:
1. The recruitment process;
2. Employee assessment and records management;
3. Employee benefits administration, including health insurance.
Dracarys will have employees on the ground in India managing the systems for the functions listed above. They have been presented with a variety of vendor options for these systems, and are currently assessing the suitability of these vendors for their needs.
The CEO of Dracarys is concerned about the behavior of her employees, especially online. After having proprietary company information being shared with competitors by former employees, she is eager to put certain measures in place to ensure that the activities of her employees, while on Dracarys' premises or when using any of Dracarys' computers and networks are not detrimental to the business.
Dracarys' external consultants are also advising the company on how to increase earnings. Dracary's management refuses to reduce production costs and compromise the quality of their garments, so the consultants suggested utilizing customer data to create targeted advertising and thus increase sales.
What must Dracarys confirm about the vendor in India in order to centralize elements of its Human Resource function?

• A. That the vendor adheres to the same sector privacy rules followed by Dracarys headquarters based in Seattle regarding the transfer of personal data.
• B. That the vendor is bound by legally enforceable obligations to provide the personal data a standard of protection that is at least comparable to the protection under the Singapore PDPA.
• C. That the vendor files requests for transfer of personal data out of India through the offices of the privacy commissioners of Hong Kong and Singapore.
• D. That the vendor submits for approval from Dracarys a privacy notice explaining how personal data will be protected under the Indian Information Technology Act.

What personal information is considered sensitive in almost all countries with privacy laws?

• A. Health information.
• B. Marital status.
• C. Employment history.
• D. Criminal convictions.

SCENARIO - Please use the following to answer the next QUESTION:
Zoe is the new Compliance Manager for the Star Hotel Group, which has five hotels across Hong Kong and Chin a. On her first day, she does an inspection of the largest property, StarOne. She starts with the hotel reception desk. Zoe sees the front desk assistant logging in to a database as he is checking in a guest. The hotel manager, Bernard, tells her that all guest data, including passport numbers, credit card numbers, home address, mobile number and other information associated with a guest's stay is held in a database. Bernard tells her not to worry about the security of the database because it is operated for Star Hotels by a local service provider called HackProof, who therefore are responsible for all the guest data.
Zoe notices what looks like a CCTV camera in the corner of the reception area. Bernard says they record all activity in the lobby. In fact, last Tuesday he had received a data access request from a lawyer requesting a copy of footage of all lobby activity for the preceding month. The lawyer's covering letter said that his client has never visited the hotel herself, but is investigating whether her husband has been doing so without her knowledge.
Zoe and Bernard head up to the hotel spa. The spa is independently owned by a company called Relax Ltd. Bernard explains that Relax Ltd is a small company and, as they don't have their own database, they transfer data about the spa guests to StarOne staff so that they can upload the data into the HackProof system. Relax Ltd staff can then login and review their guest data as needed.
Zoe asks more about the HackProof system. Bernard tells her that the server for the Hong Kong hotels is in Hong Kong, but there is a server in Shenzhen that has a copy of all the Hong Kong hotel data and supports the properties in China. The data is in China for back up purposes and also is accessible by staff in the China hotels so they can better service guests who visit their hotels in both territories.
HackProof reports to Zoe that a copy of the entire guest database has been exfiltrated by a hacker. What is Zoe's best course of action?

• A. Zoe does not need to do anything as there is no mandatory breach notification requirement in Hong Kong.
• B. Zoe must report the breach to the Privacy Commissioner and make an action plan together with the Commissioner.
• C. Zoe must immediately notify all guests, the police and the Privacy Commissioner of the breach.
• D. Zoe should consider if there is a real risk of harm to the guests and take appropriate action based on her assessment.