Jane Stan’s her new role as a Data Protection Officer (DPO) at a Malta-based company that allows anyone to buy and sell cryptocurrencies via its online platform. The company stores and processes the personal data of its customers in a dedicated data center located in Malta (EU)

SCENARIO

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Jane Stan’s her new role as a Data Protection Officer (DPO) at a Malta-based company that allows anyone to buy and sell cryptocurrencies via its online platform. The company stores and processes the personal data of its customers in a dedicated data center located in Malta (EU).

People wishing to trade cryptocurrencies are required to open an online account on the platform. They then must successfully pass a KYC due diligence procedure aimed at preventing money laundering and ensuring compliance with applicable financial regulations.

The non-European customers are also required to waive all their GDPR rights by reading a disclaimer written in bold and belong a checkbox on a separate page in order to get their account approved on the platform.

The customers must likewise accept the terms of service of the platform. The terms of service also include a privacy policy section, saying, among other things, that if a Are the cybersecurity assessors required to sign a data processing agreement with the company in order to comply with the GDPR”
A . No, the assessors do not quality as data processors as they only have access to encrypted data.
B . No. the assessors do not quality as data processors as they do not copy the data to their facilities.
C . Yes. the assessors a-e considered to be joint data controllers and must sign a mutual data processing agreement.
D . Yes, the assessors are data processors and their processing of personal data must be governed by a separate contract or other legal act.

View Answer

Answer: D