SCENARIO - Please use the following to answer the next QUESTION:
Singabank is a boutique bank in Singapore. After being notified during the hiring process, Singabank employees are subject to constant and thorough monitoring and tracking through CCTV cameras, computer monitoring software and keyboard loggers. Singabank does this to ensure its employees are complying with Singabank's data security policy. Bigbank is now considering acquiring Singabank's retail banking division. As part of its due diligence, Bigbank is seeking for Singabank to disclose to it all of its surveillance material on its employees, whether or not they are part of the retail banking division. Jimmy works in Singabank's investment banking division.
Assuming the monitoring was legal, can Singabank disclose Jimmy's personal data to Bigbank?

• A. No, because the data was collected for the express purpose of complying with Singabank's privacy policies.
• B. Yes, if Singabank informs Jimmy of the disclosure of his personal data before it occurs.
• C. Yes, if Jimmy's personal data is necessary for Bigbank to determine whether to proceed with the acquisition.
• D. No, because Jimmy is not in the division that Bigbank seeks to acquire.

SCENARIO - Please use the following to answer the next QUESTION:
Delilah is seeking employment in the marketing department of Good Mining Private Limited, an industry leader in drilling mines in Singapore. Delilah, while filling in the standard paper application form, is asked to provide details about emergency contacts, medical history, blood type and her insurance policy. These fields need to be filled in no matter which department Delilah applies to. The form also asks Delilah to expressly consent to the collection, use and disclosure of her personal data.
A week after submitting the form, Delilah is invited by Evan, the Director of Marketing at Good Mining, to coffee. Just before Delilah leaves, she gives her business card containing her current business contact information to Evan. Evan then uses the business card to add Delilah's details to Good Mining's business development database, which is kept on a local server. Good Mining uses the database to inform people about networking and client events that Good Mining organizes.
Why is it legal for Evan to add the information on Delilah's business card to the business development database?

• A. Because Delilah initiated the relationship with Good Mining.
• B. Because any business contact information can be freely used, collected or disclosed by Good Mining.
• C. Because Delilah "consented" to her business contact information being used by Good Mining by passing it to Evan voluntarily.
• D. Because Good Mining does not export the information to a cloud vendor.

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.
Assuming that Section 33 is in force, which of the following would NOT help Zoe to facilitate the cross-border transfer from Hong Kong to China?

• A. Amending StarOne's privacy policy to refer to the transfer.
• B. Consent of the guest in writing to the transfer.
• C. China being included as a "White List" country for data transfer.
• D. Putting in place Model Clauses between the relevant entities.

What benefit does making data pseudonymous offer to data controllers?

• A. It eliminates the need for a policy specifying data subject access rights.
• B. It ensures that it is impossible to re-identify the data.
• C. It allows for further use of the data for research purposes.
• D. It eliminates the responsibility to report data breaches.