QuestionQ23

Privacy Program Framework

Which option best describes proper compliance by an international organization that uses Binding Corporate Rules (BCRs) as a controller or processor?

  • A Employees must sign an ad hoc contractual agreement each time personal data is exported.
  • B All employees are subject to the rules in their entirety, regardless of where the work is taking place.
  • C All employees must follow the privacy regulations of the jurisdictions where the current scope of their work is established.
  • D Employees who control personal data must complete a rigorous certification procedure, as they are exempt from legal enforcement.
Explanation

Binding Corporate Rules must be legally binding and must apply to and be enforced by every concerned member of the corporate group, including its employees. They provide a group-wide framework for protected international personal-data transfers rather than requiring separate ad hoc agreements or exempting employees from enforcement.

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