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Anyone take the CIPM recently? How was it?
Can you incorporate SCCs by reference in a DPA?
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I’d start with giving “yes, if” (if they exist). Such as, yes we can do that if we limit it to xyz data, give notice at collection, etc. This can help show what goes into their idea and puts you on their side rather than just saying no. After I’ve shown I’ve tried to find a solution I’d talk about fines and reputational harm.
Avoid the outright “no” but be clear about the risks and consequences after trying to work through ways to accomplish the desired result.
Enthusiast
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