SCENARIO - Please Use the Following to Answer the Next

question 23

Multiple Choice

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. Dracary's existing client data sets have been anonymised but the CEO is concerned about re-identification and the risks of using the data for further analysis. What should the CEO do?

• A) Assess the business risk of further processing in the absence of any regulations on anonymised data.
• B) Refer to India's Information Technology Act and the 2011 rules 3-8 for guidance on handling anonymised data.
• C) Obtain the consent of the data subjects because anonymous data must be treated as personal data at all times.
• D) Adhere to the Singapore guidelines on anonymization and the Hong Kong Guidance on Personal Data Erasure and Anonymization.

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Definitions:

College Degree

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