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CIPP-A Exam - Question 14


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?

Show Answer
Correct Answer: CD

Singabank can disclose Jimmy's personal data to Bigbank if it is necessary for Bigbank to determine whether to proceed with the acquisition. In the context of due diligence during an acquisition, such disclosures are typically allowed under data protection laws, like the business asset transaction exception under the Personal Data Protection Act (PDPA) in Singapore. This exception allows for the transfer of personal data without explicit consent when it is necessary for the purposes of a business transaction. Therefore, option D is the correct answer.

Discussion

4 comments
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187b1e6Option: D
Mar 2, 2024

should be D

rhyst1921Option: D
Mar 25, 2024

D, as this would likely fall under the business asset transaction exception from consent obligation under the PDPA.

rhyst1921Option: A
Mar 25, 2024

C would be correct IF Jimmy's consent was sought, however in this option C, it is incorrect because simply notification is insufficient.

BhimeshOption: D
Mar 31, 2024

D. Yes