Abstract
International organisations are no less likely to be the target (and therefore the potential victim) of fraudulent behaviour by members of the public than anyone else. Indeed international organisations are frequently even deliberately targeted specifically because their staff may be known in a wide range of jurisdictions and because of the numerous high-value transactions that are regularly being conducted (in a range of currencies and with a range of potential beneficiaries), hence the possible chance to introduce a false or deceptive claim and gain significant benefits of a fraudulent transaction.
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FCPA Blog article entitled ‘GDPR: What are the grounds for processing personal data during an investigation?’ by Lara White, Andrew Reeves and Sarah Greenwood, dated September 10, 2019 which notes that: ‘The GDPR applies to organisations that are established in the EU (regardless of whether the personal data that they process is of EU data subjects or not). The GDPR also applies to the processing of personal data by non-EU entities, where such processing is in the context of offering goods or services to data subjects in the EU or in the context of monitoring of the behaviour of data subjects in the EU’ and that personal data is ‘defined very broadly in the GDPR as any information relating to an identified or identifiable natural person. In practice this means that data collections and reviews will nearly always involve the processing of personal data’. Also, the article notes that it is ‘much more difficult to rely on an employee’s consent as a grounds for processing’ and that ‘If consent cannot be relied on, another ground for processing will need to be identified (usually the employer’s legitimate interest in reviewing the data)’.
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Smith, D. (2021). Cyber Crime, Data Security and Data Protection. In: Promoting Integrity in the Work of International Organisations . Contributions to Finance and Accounting. Springer, Cham. https://doi.org/10.1007/978-3-030-73916-4_5
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DOI: https://doi.org/10.1007/978-3-030-73916-4_5
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Publisher Name: Springer, Cham
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Online ISBN: 978-3-030-73916-4
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