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PECB GDPR Exam - Topic 3 Question 16 Discussion

Posted by Ashanti on May 06, 2026 at 11:10 PM

Scenario 1:

MED is a healthcare provider located in Norway. It provides high-quality and affordable healthcare services, including disease prevention, diagnosis, and treatment. Founded in 1995, MED is one of the largest health organizations in the private sector. The company has constantly evolved in response to patients' needs.

Patients that schedule an appointment in MED's medical centers initially need to provide their personal information, including name, surname, address, phone number, and date of birth. Further checkups or admission require additional information, including previous medical history and genetic dat

a. When providing their personal data, patients are informed that the data is used for personalizing treatments and improving communication with MED's doctors. Medical data of patients, including children, are stored in the database of MED's health information system. MED allows patients who are at least 16 years old to use the system and provide their personal information independently. For children below the age of 16, MED requires consent from the holder of parental responsibility before processing their data.

MED uses a cloud-based application that allows patients and doctors to upload and access information. Patients can save all personal medical data, including test results, doctor visits, diagnosis history, and medicine prescriptions, as well as review and track them at any time. Doctors, on the other hand, can access their patients' data through the application and can add information as needed.

Patients who decide to continue their treatment at another health institution can request MED to transfer their data. However, even if patients decide to continue their treatment elsewhere, their personal data is still used by MED. Patients' requests to stop data processing are rejected. This decision was made by MED's top management to retain the information of everyone registered in their databases.

The company also shares medical data with InsHealth, a health insurance company. MED's data helps InsHealth create health insurance plans that meet the needs of individuals and families.

MED believes that it is its responsibility to ensure the security and accuracy of patients' personal data. Based on the identified risks associated with data processing activities, MED has implemented appropriate security measures to ensure that data is securely stored and processed.

Since personal data of patients is stored and transmitted over the internet, MED uses encryption to avoid unauthorized processing, accidental loss, or destruction of data. The company has established a security policy to define the levels of protection required for each type of information and processing activity. MED has communicated the policy and other procedures to personnel and provided customized training to ensure proper handling of data processing.

Questio n:

Based on scenario 1, is the processing of children's personal data performed by MED in compliance with GDPR?

Suggested Answer: B

Under Article 8 of the GDPR, the processing of personal data of children under 16 years is only lawful if parental or guardian consent is obtained. However, Member States can lower the age limit to 13 years if they choose.

In this scenario, MED requires parental consent for children below 16 years, which aligns with GDPR requirements. Therefore, Option B is correct. Option A is incorrect because GDPR allows parental consent. Option C is incorrect because GDPR does not require explicit consent from the child when parental consent is given. Option D is incorrect because encryption alone does not determine compliance.


GDPR Article 8 (Conditions for children's consent)

Recital 38 (Protection of children's data)

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24 comments · newest first
VE
Velda 2 days ago
I think option B is correct. Parental consent is enough.
CH
Christiane 7 days ago
D is misleading. Security alone isn't compliance.
DE
Devon 12 days ago
A is important. We can't overlook GDPR's intent.
ER
Erinn 17 days ago
C makes sense. Kids should have a say in their data.
CL
Clare 23 days ago
I agree with B. MED follows the rules with consent.
FR
Francesco 28 days ago
D is too lenient. Encryption doesn't solve everything.
TI
Timothy 1 month ago
A seems right. GDPR is strict about kids' data.
BE
Bernadine 1 month ago
But what about C? Kids should consent too.
LY
Lynda 1 month ago
I think it's B. Parental consent is enough.
BR
Brock 2 months ago
I agree with Lily. Consent is key, not just security.
SH
Sheron 2 months ago
D is not enough. Encryption doesn't cover consent issues.
LI
Linette 2 months ago
But MED has parental consent, so B is valid.
KR
Kristeen 2 months ago
I feel like A is right. GDPR is strict about kids' data.
CA
Caitlin 2 months ago
I disagree, Jenna. C makes more sense. Kids should consent too.
AV
Avery 2 months ago
I think it's B. Parental consent is enough.
BA
Barbra 3 months ago
I’m surprised they don’t need explicit consent from the kids too!
MA
Maile 3 months ago
Encryption alone doesn't make it compliant, so option D is a no-go.
NI
Nieves 3 months ago
Wait, can they really keep using our data even if we leave?
SH
Shelton 3 months ago
Definitely agree with option B!
AN
Antonio 3 months ago
I think parental consent is enough for GDPR compliance.
JO
Josphine 4 months ago
I'm a bit confused about option C; I thought parental consent was enough, but now I'm wondering if the child needs to agree too.
RU
Ruthann 5 months ago
I feel like I saw a similar question in practice exams, and it was about the age of consent for data processing. I think it was also about needing parental consent.
FR
Frederica 5 months ago
I think option B sounds right because it mentions parental consent, which I recall is necessary for children under 16 according to GDPR.
ST
Stephane 5 months ago
I remember studying that GDPR requires parental consent for processing children's data, but I'm not sure if it has to be explicit or just informed consent.
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