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Scenario:Pinky, a retail company,received a requestfrom adata subjectto identify which purchasesthey had madeat differentphysical store...

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Scenario:

Pinky, a retail company,received a requestfrom adata subjectto identify which purchasesthey had madeat differentphysical store locations. However,Pinky does not link purchase records to customer identities, since purchasesdo not require account creation.

Question:

Should Pinkyprocess additional informationfrom customers in order toidentify the data subjectas requested?

A.

Yes, Pinky is required tomaintain, acquire, or process additional informationin order to identify the data subject.

B.

Yes, Pinky is required to process additional information for the purpose ofexercising the data subject’s rightscovered inArticles 15-21 of GDPR.

C.

No, Pinky isnot requiredto process additional information, since the processing of personal data in this case does not require Pinky toidentify the data subject.

D.

No, but Pinky must ask the data subject to provide further evidence proving their identity.

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