Question 1

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

China. 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?

Options :

A : Zoe must immediately notify all guests, the police and the Privacy Commissioner of the breach

B : Zoe does not need to do anything as there is no mandatory breach notification requirement in Hong Kong

C : Zoe must report the breach to the Privacy Commissioner and make an action plan together with the Commissioner

D : Zoe should consider if there is a real risk of harm to the guests and take appropriate action based on her assessment

Answer: D

Question 2

What term is defined by the European Commission to mean any data that relates to an identified or identifiable individual?

Options :

A : Personally identifiable information.

B : Sensitive information.

C : Personal data

D : Identified data.

Answer: C

Question 3

According to India's IT Rules 2011, a body corporate operating in India is required to appoint what kind of authority?

Options :

A : A Chief Risk Officer.

B : A Grievance Officer.

C : A Data Protection Officer.

D : A Chief Technology Officer.

Answer: B

Question 4

Who is NOT potentially liable when an employee in a Singapore corporation or partnership breaches the PDPA?

Options :

A : A corporate officer.

B : The employee.

C : The employer

D : A partner.

Answer: A

Question 5

Which of the following is NOT excluded from the scope of Singapore's Do Not Call registry?

Options :

A : Messages that promote investment opportunities.

B : Messages that conduct market research.

C : Messages from charitable organizations

D : Messages from political candidates.

Answer: B

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