Certified Information Privacy Professional – Europe (CIPP/E) — Question 271

SCENARIO -
Please use the following to answer the next question:

Gentle Hedgehog Inc. is a privately owned website design agency incorporated in Italy. The company has numerous remote workers in different EU countries. Recently, the management of Gentle Hedgehog noticed a decrease in productivity of their sales team, especially among remote workers. As a result, the company plans to implement a robust but privacy-friendly remote surveillance system to prevent absenteeism, reward top performers, and ensure the best quality of customer service when sales people are interacting with customers.

Gentle Hedgehog eventually hires Sauron Eye Inc., a Chinese vendor of employee surveillance software whose European headquarters is in Germany. Sauron Eye s software provides powerful remote-monitoring capabilities, including 24/7 access to computer cameras and microphones, screen captures, emails, website history, and keystrokes. Any device can be remotely monitored from a central server that is securely installed at Gentle Hedgehog headquarters. The monitoring is invisible by default; however, a so-called Transparent Mode, which regularly and conspicuously notifies all users about the monitoring and its precise scope, also exists. Additionally, the monitored employees are required to use a built-in verification technology involving facial recognition each time they log in.

All monitoring data, including the facial recognition data, is securely stored in Microsoft Azure cloud servers operated by Sauron Eye, which are physically located in France.

Based on the scenario, what are the primary privacy risks of the planned surveillance system?

Answer options

• A. A Chinese vendor and the monitoring of EU-based employees.
• B. Facial recognition data stored in the cloud and lack of encryption.
• C. Excessive scope of monitoring and lack of legitimate purpose for data collection.
• D. Missing E2EE encryption in the monitoring system and unclear data storage duration.

Correct answer: C

Explanation

The correct answer, C, highlights the excessive monitoring practices which may violate privacy regulations, as well as the absence of a legitimate purpose for collecting data. Option A points to the vendor's origin, which is relevant but not as critical as the monitoring scope. Option B mentions facial recognition and encryption but does not address the broader implications of excessive surveillance. Option D discusses encryption and data storage duration, which are concerns but less central than the overarching privacy risks in C.