Page 2

INFO5301 Data Privacy and General Data Protection Regulation

by Union or Member State law, the controller or the specific criteria for its nomination

may be provided for by Union or Member State law;

• ‘processor’ means a natural or legal person, public authority, agency or other body

which processes personal data on behalf of the controller;

• ‘personal data breach’ means a breach of security leading to the accidental or unlawful

destruction, loss, alteration, unauthorised disclosure of, or access to, personal data

transmitted, stored or otherwise processed;

1.3 Who is primarily concerned by the GDPR? (Hint: Chapter 1, Art: 3)

Answer: EU citizens and all bodies processing their data.

This Regulation applies to the processing of personal data in the context of the activities

of an establishment of a controller or a processor in the Union, regardless of whether the

processing takes place in the Union or not.

The data subject is defined as a natural person, e.g. a citizen of any EU country or of another

country. The controller is a natural or legal person. The controller determines the purposes

and conditions for the processing of personal data, e.g. profit companies, non-profit com-

panies, governments, state agencies and people. The processor is a natural or legal person

who processes personal data on behalf of the controller, e.g. an IT vendor. The GDPR places

various obligations on the controller, which is the body ultimately responsible for the law-

ful processing of personal data. Controllers should only use processors that can meet the

requirements of lawful personal data processing prescribed by the GDPR.

1.4 What is considered as lawful consent in the GDPR? (Hint: Chapter 2, Art: 7, Look into

the suitable recitals as well.)

1. A continuation of navigation on a site or a mobile application by a simple scroll.

2. The simple act of downloading a document from a site or mobile application.

3. A clear affirmative act by which the person freely expresses, in a specific and informed

manner, their consent to data processing.

Answer: (3)

According to the GDPR, consent should be given by a clear positive act by which the data

subject freely, specifically, informed and unequivocally expresses his or her consent to the

processing of personal data – for example by means of a written declaration, including by

electronic means, or an oral declaration. This could be done by ticking a box when con-

sulting a website, by opting for certain technical parameters for IT services or by means

of another statement or other behaviour clearly indicating that the data subject accepts the

proposed processing of their personal data. There can therefore be no consent in the event

of silence, default ticked boxes or inactivity. Consent given should apply to all processing

activities with the same purpose(s). Where the processing has several purposes, consent

should be given for all of them. If the data subject’s consent is given following an electronic

request, the request must be clear and concise and must not unnecessarily disrupt the use of

the service for which it is granted.

Information Security Management Page 2of 6