Question 76

In 2016's Guidance, the United Kingdom's Information Commissioner's Office (ICO) reaffirmed the importance of using a "layered notice" to provide data subjects with what?
  • Question 77

    As a result of the European Court of Justice's ruling in the case of Google v. Spain, search engines outside the EEA are also likely to be subject to the Regulation's right to be forgotten. This holds true if the activities of an EU subsidiary and its U.S. parent are what?
  • Question 78

    When does the European Data Protection Board (EDPB) recommend reevaluating whether a transfer tool is effectively providing a level of personal data protection that is in compliance with the European Union (EU) level?
  • Question 79

    Which mechanism, new to the GDPR, now allows for the possibility of personal data transfers to third countries under Article 42?
  • Question 80

    SCENARIO
    Please use the following to answer the next question:
    Building Block Inc. is a multinational company, headquartered in Chicago with offices throughout the United States, Asia, and Europe (including Germany, Italy, France and Portugal). Last year the company was the victim of a phishing attack that resulted in a significant data breach. The executive board, in coordination with the general manager, their Privacy Office and the Information Security team, resolved to adopt additional security measures. These included training awareness programs, a cybersecurity audit, and use of a new software tool called SecurityScan, which scans employees' computers to see if they have software that is no longer being supported by a vendor and therefore not getting security updates. However, this software also provides other features, including the monitoring of employees' computers.
    Since these measures would potentially impact employees, Building Block's Privacy Office decided to issue a general notice to all employees indicating that the company will implement a series of initiatives to enhance information security and prevent future data breaches.
    After the implementation of these measures, server performance decreased. The general manager instructed the Security team on how to use SecurityScan to monitor employees' computers activity and their location.
    During these activities, the Information Security team discovered that one employee from Italy was daily connecting to a video library of movies, and another one from Germany worked remotely without authorization.
    The Security team reported these incidents to the Privacy Office and the general manager. In their report, the team concluded that the employee from Italy was the reason why the server performance decreased.
    Due to the seriousness of these infringements, the company decided to apply disciplinary measures to both employees, since the security and privacy policy of the company prohibited employees from installing software on the company's computers, and from working remotely without authorization.
    What would be the MOST APPROPRIATE way for Building Block to handle the situation with the employee from Italy?