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SCENARIO Please use the following to answer the next question: Sandy recently joined Market4U, an advertising technology company founded in 2016, as their VP of Privacy and Data Governance. Through her first initiative in conducting a data inventory, Sandy learned that Market4U maintains a list of 19 million global contacts that were collected throughout the course of Market4U's existence. Knowing the risk of having such a large amount of data, Sandy wanted to purge all contacts that were entered into Market4U's systems prior to May 2018, unless such contacts had a more recent interaction with Market4U content. However, Dan, the VP of Sales, informed Sandy that all of the contacts provide useful information regarding successful marketing campaigns and trends in industry verticals for Market4U's clients. Dan also informed Sandy that he had wanted to focus on gaining more customers within the sports and entertainment industry. To assist with this behavior, Market4U's marketing team decided to add several new fields to Market4U's website forms, including forms for downloading white papers, creating accounts to participate in Market4U's forum, and attending events. Such fields include birth date and salary. What should Sandy give as feedback to Dan and the marketing team regarding the new fields Dan wants to add to Market4U's forms?
Correct Answer: D
Sandy should give this feedback to Dan and the marketing team, as it reflects the principle of data minimization, which requires that personal data collected must be adequate, relevant and limited to what is necessary for the purposes of the processing1. Collecting birth date and salary information from customers who want to download white papers or register for events is not necessary for those purposes, and may pose risks for data protection and security. Moreover, such information may fall under the category of special data, which requires explicit consent from the data subjects and can only be processed under certain conditions2. The other options do not comply with the principle of data minimization, as they still involve collecting more data than needed, even if they are optional or in brackets. Reference: Free CIPP/E Study Guide, page 23, section 3.1 CIPP/E Certification, page 18, section 3.1 The Ultimate CIPP/E Study Guide for 2023, page 16, section 3.1 Principles - General Data Protection Regulation (GDPR), Article 5 Special categories of personal data - General Data Protection Regulation (GDPR), Article 9