We’ve covered this above, I anticipate Santa has a appealing acceptable butt on the admonition he has.
Due to the logistical accountability on his operation (how abounding ability delivered in how long?!) he is acceptable to be antipathetic of any cardboard annal above the allowance tags or abode labels on item. I apprehend his sleigh to accept a bombastic IT systems (2 iPads) with bombastic accessory connectivity.
Article 6 provides some amount options:
I would admonish Santa use the ‘vital interests’ and ‘legitimate interests’ (of the parents/guardians) as accessible altitude for processing.
Offshore through Amazon Web Services. WorkSpaces are acclimated for GUI representation and active queries with Oracle RDS captivation all of the data.
Lambda is acclimated for automatic processing such as tallying the all-embracing Abstracts Accountable naughty-v-nice account over the year (from the aftermost Christmas until the absolute point by which Santa needs a accommodation to accomplish the allowance in time).
Pretty abundant anybody in Santa’s organisation, on the base that they are all goal/mission orientated — even Rudolf needs to apperceive area to go.
Elves should alone be able to admission Abstracts Accountable admonition as allotment of their work, so the adapted Abstracts Accountable admonition at the adapted time for the adapted duration — if they are authoritative Joe’s toy, they can alone see Joe’s admonition (and bound scope) at that time — naughty-v-nice score, toy preferences etc.
Limited scopes are important based on context — Elves don’t charge to apperceive the abode of the Abstracts Accountable while authoritative a allowance but they may charge addresses (but not scores) back allowance Santa backpack his sleigh.
Santa is acceptable operating as a sole banker in this bearings as he isn’t afraid about sales taxes etc.
Santa is operating a ample organisation so should accede appointing a Abstracts Protection Officer (DPO). The DPO charge accept absolute admission to the accomplished akin of administration in the organisation and can action admonition and while Mrs Claus is in battle (and appropriately cannot be DPO) she would in approach be an able one as she could accomplish abiding Santa sleeps on the couch if there was a Abstracts Breach — this ability action the European Court of Amends (ECJ) some balmy aberrant acknowledgment that some amends has been served.
Santa acceptable gets his abstracts from authoritative annal (registering a bearing workflows etc) — although I do doubtable this is ‘extra legal’ due to abridgement of academic abstracts administration capabilities.
I would acerb acclaim Santa actualize the North Pole as a area and accomplish UN recognition, in adjustment to again bureaucracy abstracts administration agreements with anniversary ambition country.
Once Santa holds this bearing information, he can account age. But he needs to accumulate addresses up to date, so acceptable is affairs copies of balloter abstracts through abstracts brokers who aren’t too afraid about acknowledged jurisdictions. Abode abstracts is parent/guardian linked, so he acutely has admission to a deluge of education, amusing affliction and bounded state/authority abstracts to be able to consistently articulation a Abstracts Accountable adolescent with parents/guardians.
Using ‘extra legal’ bureau Santa may be re-washing his abstracts with added abstracts sources (other government databases etc) in adjustment to accumulate things as authentic as he can — as abstracts analogous is adamantine and a single-source of accuracy is actual difficult to find.
Santa acceptable programmatically monitors databases for deaths and change of name. A few Elves may be committed to the aberrant job of ecology hospital databases and obituary publications.
(I am added afraid about how we assure databases from Santa — but I would admonish any organisation to accede Santa forth with all added accompaniment actors but conceivably in a milder faculty accustomed Santa’s motivations are not to be harmful.)
Article 13 does not administer (Santa doesn’t get abstracts anon from Abstracts Subjects) so Santa is actual acceptable in contravention of Article 14 as to my ability there is no appear or readily accessible aloofness apprehension carrying processing information.
Santa is absurd to accept any applicative exemptions in this attention (such as recognisable civic aegis exemptions) that alibi him from defective to accommodate processing information.
Santa’s organisation acceptable uses up to date macOS accessories because Santa is still afire VC banknote all these years later.
As the macOS accessories are alone acclimated for work, Internet connectivity to get to the AWS WorkSpaces and appropriately advanced into the Oracle RDS is a acceptable solution.
EUCS controls through the JAMF accessory administration band-aid anticipate the Elves from accidentally exporting copies of abstracts and ensure the bounded accessory is encrypted at-rest.
Santa has paid $$$$ to AWS and he has the Oracle RDS band-aid tiers which acquiesce encryption in-transit.
Santa advised all the FVEY bureau advice and prefers the UK Civic Cyber Aegis Centre (NCSC) ones the most — so ensures he follows their end-user accessory guidance, IPSec & TLS agreement guides and more.
Santa does accept a Bring-Your-Own-Device (BYOD) action (based on the UK Ministry of Justice’s accessible antecedent IT action agreeable repository) but he doesn’t pay the Elves abundant to accept their own claimed accessories so this isn’t an affair (well, in this forum — labour laws in the North Pole are sketchy)
No absolute antagonism for Santa appears to abide so agents are absurd to be accountable to accumulated espionage or added such influences/motivations appropriately Santa is absolutely blessed with his central amateur accident (he perceives it added as careless adventitious breaches than advised bad actor).
Santa has ensured that he has leveraged the aggregate albatross models with AWS to ensure that they are amenable for article abstruse aegis such as patching, attention adjoin Denial of Service (DoS) attacks and so on.
Santa tends to get added ‘request’ belletrist than annihilation abroad so he sees this as a Article 16 (‘Right to Rectification’) over Article 15 (‘Right of access’).
Santa doesn’t accede with Article 17 (‘Right to erasure’) as his acquaintance tells him either the Abstracts Accountable ages out of his scope, actual acutely passes abroad or the Abstracts Accountable is ‘naughty’ and the adapted is not empiric as he is assertive on carrying coal. Similarly, Santa action in the face of any restrictions (Article 18) or objections (Article 21).
Santa does not accede Article 20 (‘Right to abstracts portability’) article he will be faced with due to abridgement of absolute competition, and the best antagonism stemming from parents/guardians or added assembly who acceptable accept the aforementioned information. Santa is afraid to accede as he additionally believes this would accommodate accuracy to the added acknowledged methods he takes to admission Claimed Data.
Due to Santa’s blurred position on how array are tallied and ability absitively upon, we’ll accept to see what Santa’s position on Article 22 (‘Automated accommodation authoritative / profiling’) is.
Santa cackles in the face of any restrictions (Article 23) because he has arrested his account at atomic alert and is adequate in the acknowledged ambiguity the North Pole provides.
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