CIPP-E Exam Questions – Certified Information Privacy Professional/Europe (CIPP/E)

The Certified Information Privacy Professional/Europe (CIPP/E) delivers the comprehensive GDPR knowledge, perspective and understanding to ensure compliance and data protection success in Europe—equipping DPOs to take advantage of the career opportunity this sweeping legislation represents.

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CIPP-E Exam Questions – Certified Information Privacy Professional/Europe (CIPP/E)

1. Which statement is correct when considering the right to privacy under Article 8 of the European Convention on Human Rights (ECHR)?

The right to privacy is an absolute right

The right to privacy has to be balanced against other rights under the ECHR

The right to freedom of expression under Article 10 of the ECHR will always override the right to privacy

The right to privacy protects the right to hold opinions and to receive and impart ideas without interference

2. What is one major goal that the OECD Guidelines, Convention 108 and the Data Protection Directive (Directive 95/46/EC) all had in common but largely failed to achieve in Europe?

The establishment of a list of legitimate data processing criteria

The creation of legally binding data protection principles

The synchronization of approaches to data protection

The restriction of cross-border data flow

3. A key component of the OECD Guidelines is the “Individual Participation Principle”.

What parts of the General Data Protection Regulation (GDPR) provide the closest equivalent to that principle?

The lawful processing criteria stipulated by Articles 6 to 9

The information requirements set out in Articles 13 and 14

The breach notification requirements specified in Articles 33 and 34

The rights granted to data subjects under Articles 12 to 22

4. Which EU institution is vested with the competence to propose new data protection legislation on its own initiative?

The European Council

The European Parliament

The European Commission

The Council of the European Union

5. What is an important difference between the European Court of Human Rights (ECHR) and the Court of Justice of the European Union (CJEU) in relation to their roles and functions?

ECHR can rule on issues concerning privacy as a fundamental right, while the CJEU cannot.

CJEU can force national governments to implement and honor EU law, while the ECHR cannot.

CJEU can hear appeals on human rights decisions made by national courts, while the ECHR cannot.

ECHR can enforce human rights laws against governments that fail to implement them, while the CJEU cannot.

6. SCENARIO

Please use the following to answer the next question:

Anna and Frank both work at Granchester University. Anna is a lawyer responsible for data protection, while Frank is a lecturer in the engineering department.

The University maintains a number of types of records:

– Student records, including names, student numbers, home addresses, pre-university information,

university attendance and performance records, details of special educational needs and financial

information.

– Staff records, including autobiographical materials (such as curricula, professional contact files, student evaluations and other relevant teaching files).

– Alumni records, including birthplaces, years of birth, dates of matriculation and conferrals of degrees. These records are available to former students after registering through Granchester’s Alumni portal.

– Department for Education records, showing how certain demographic groups (such as first-generation students) could be expected, on average, to progress. These records do not contain names or identification numbers.

– Under their security policy, the University encrypts all of its personal data records in transit and at rest.

In order to improve his teaching, Frank wants to investigate how his engineering students perform in relational to Department for Education expectations. He has attended one of Anna’s data protection training courses and knows that he should use no more personal data than necessary to accomplish his goal. He creates a program that will only export some student data: previous schools attended, grades originally obtained, grades currently obtained and first time university attended. He wants to keep the records at the individual student level. Mindful of Anna’s training, Frank runs the student numbers through an algorithm to transform them into different reference numbers. He uses the same algorithm on each occasion so that he can update each record over time.

One of Anna’s tasks is to complete the record of processing activities, as required by the GDPR. After receiving her email reminder, as required by the GDPR. After receiving her email reminder, Frank informs Anna about his performance database.

Ann explains to Frank that, as well as minimizing personal data, the University has to check that this new use of existing data is permissible. She also suspects that, under the GDPR, a risk analysis may have to be carried out before the data processing can take place. Anna arranges to discuss this further with Frank after she has done some additional research.

Frank wants to be able to work on his analysis in his spare time, so he transfers it to his home laptop (which is not encrypted). Unfortunately, when Frank takes the laptop into the University he loses it on the train. Frank has to see Anna that day to discuss compatible processing. He knows that he needs to report security incidents, so he decides to tell Anna about his lost laptop at the same time.

Which of the University’s records does Anna NOT have to include in her record of processing activities?

Student records

Staff and alumni records

Frank’s performance database

Department for Education records

7. Which institution has the power to adopt findings that confirm the adequacy of the data protection level in a non-EU country?

The European Parliament

The European Commission

The Article 29 Working Party

The European Council

8. What is true of both the General Data Protection Regulation (GDPR) and the Council of Europe Convention 108?

Both govern international transfers of personal data

Both govern the manual processing of personal data

Both only apply to European Union countries

Both require notification of processing activities to a supervisory authority

9. Which aspect of the GDPR will likely have the most impact on the consistent implementation of data protection laws throughout the European Union?

That it essentially functions as a one-stop shop mechanism

That it takes the form of a Regulation as opposed to a Directive

That it makes notification of large-scale data breaches mandatory

That it makes appointment of a data protection officer mandatory

10. How is the retention of communications traffic data for law enforcement purposes addressed by European data protection law?

The ePrivacy Directive allows individual EU member states to engage in such data retention.

The ePrivacy Directive harmonizes EU member states’ rules concerning such data retention.

The Data Retention Directive’s annulment makes such data retention now permissible.

The GDPR allows the retention of such data for the prevention, investigation, detection or prosecution of criminal offences only.

11. What type of data lies beyond the scope of the General Data Protection Regulation?

Pseudonymized

Anonymized

Encrypted

Masked

12. Under what circumstances would the GDPR apply to personal data that exists in physical form, such as information contained in notebooks or hard copy files?

Only where the personal data is produced as a physical output of specific automated processing activities, such as printing, labelling, or stamping.

Only where the personal data is to be subjected to specific computerized processing, such as image scanning or optical character recognition.

Only where the personal data is treated by automated means in some way, such as computerized distribution or filing.

Only where the personal data is handled in a sufficiently structured manner so as to form part of a filing system.

13. SCENARIO

Please use the following to answer the next question:

You have just been hired by a toy manufacturer based in Hong Kong. The company sells a broad range of dolls, action figures and plush toys that can be found internationally in a wide variety of retail stores. Although the manufacturer has no offices outside Hong Kong and in fact does not employ any staff outside Hong Kong, it has entered into a number of local distribution contracts. The toys produced by the company can be found in all popular toy stores throughout Europe, the United States and Asia. A large portion of the company’s revenue is due to international sales.

The company now wishes to launch a new range of connected toys, ones that can talk and interact with children. The CEO of the company is touting these toys as the next big thing, due to the increased possibilities offered: The figures can answer children’s questions on various subjects, such as mathematical calculations or the weather. Each figure is equipped with a microphone and speaker and can connect to any smartphone or tablet via Bluetooth. Any mobile device within a 10-meter radius can connect to the toys via Bluetooth as well. The figures can also be associated with other figures (from the same manufacturer) and interact with each other for an enhanced play experience.

When a child asks the toy a question, the request is sent to the cloud for analysis, and the answer is generated on cloud servers and sent back to the figure. The answer is given through the figure’s integrated speakers, making it appear as though that the toy is actually responding to the child’s question. The packaging of the toy does not provide technical details on how this works, nor does it mention that this feature requires an internet connection. The necessary data processing for this has been outsourced to a data center located in South Africa.

However, your company has not yet revised its consumer-facing privacy policy to indicate this.

In parallel, the company is planning to introduce a new range of game systems through which consumers can play the characters they acquire in the course of playing the game. The system will come bundled with a portal that includes a Near-Field Communications (NFC) reader. This device will read an RFID tag in the action figure, making the figure come to life onscreen. Each character has its own stock features and abilities, but it is also possible to earn additional ones by accomplishing game goals. The only information stored in the tag relates to the figures’ abilities. It is easy to switch characters during the game, and it is possible to bring the figure to locations outside of the home and have the character’s abilities remain intact.

Why is this company obligated to comply with the GDPR?

The company has offices in the EU.

The company employs staff in the EU.

The company’s data center is located in a country outside the EU.

The company’s products are marketed directly to EU customers.

14. Which of the following would most likely NOT be covered by the definition of “personal data” under the GDPR?

The payment card number of a Dutch citizen

The U.S. social security number of an American citizen living in France

The unlinked aggregated data used for statistical purposes by an Italian company

The identification number of a German candidate for a professional examination in Germany

15. Which of the following would MOST likely trigger the extraterritorial effect of the GDPR, as specified by Article 3?

The behavior of suspected terrorists being monitored by EU law enforcement bodies.

Personal data of EU citizens being processed by a controller or processor based outside the EU.

The behavior of EU citizens outside the EU being monitored by non-EU law enforcement bodies.

Personal data of EU residents being processed by a non-EU business that targets EU customers.

16. How does the GDPR now define “processing”?

Any act involving the collecting and recording of personal data.

Any operation or set of operations performed on personal data or on sets of personal data.

Any use or disclosure of personal data compatible with the purpose for which the data was collected.

Any operation or set of operations performed by automated means on personal data or on sets of personal data.

17. What is the consequence if a processor makes an independent decision regarding the purposes and means of processing it carries out on behalf of a controller?

The controller will be liable to pay an administrative fine

The processor will be liable to pay compensation to affected data subjects

The processor will be considered to be a controller in respect of the processing concerned

The controller will be required to demonstrate that the unauthorized processing negatively affected one or more of the parties involved

18. According to the GDPR, how is pseudonymous personal data defined?

Data that can no longer be attributed to a specific data subject without the use of additional information kept separately.

Data that can no longer be attributed to a specific data subject, with no possibility of re-identifying the data.

Data that has been rendered anonymous in such a manner that the data subject is no longer identifiable.

Data that has been encrypted or is subject to other technical safeguards.

19. Under which of the following conditions does the General Data Protection Regulation NOT apply to the processing of personal data?

When the personal data is processed only in non-electronic form

When the personal data is collected and then pseudonymised by the controller

When the personal data is held by the controller but not processed for further purposes

When the personal data is processed by an individual only for their household activities

20. According to the E-Commerce Directive 2000/31/EC, where is the place of “establishment” for a company providing services via an Internet website confirmed by the GDPR?

Where the technology supporting the website is located

Where the website is accessed

Where the decisions about processing are made

Where the customer’s Internet service provider is located

21. Which statement is correct when considering the right to privacy under Article 8 of the European Convention on Human Rights (ECHR)?

The right to privacy is an absolute right

The right to privacy has to be balanced against other rights under the ECHR

The right to freedom of expression under Article 10 of the ECHR will always override the right to privacy

The right to privacy protects the right to hold opinions and to receive and impart ideas without interference

22. What is one major goal that the OECD Guidelines, Convention 108 and the Data Protection Directive (Directive 95/46/EC) all had in common but largely failed to achieve in Europe?

The establishment of a list of legitimate data processing criteria

The creation of legally binding data protection principles

The synchronization of approaches to data protection

The restriction of cross-border data flow

23. A key component of the OECD Guidelines is the “Individual Participation Principle”.

What parts of the General Data Protection Regulation (GDPR) provide the closest equivalent to that principle?

The lawful processing criteria stipulated by Articles 6 to 9

The information requirements set out in Articles 13 and 14

The breach notification requirements specified in Articles 33 and 34

The rights granted to data subjects under Articles 12 to 22

24. Which EU institution is vested with the competence to propose new data protection legislation on its own initiative?

The European Council

The European Parliament

The European Commission

The Council of the European Union

25. What is an important difference between the European Court of Human Rights (ECHR) and the Court of Justice of the European Union (CJEU) in relation to their roles and functions?

ECHR can rule on issues concerning privacy as a fundamental right, while the CJEU cannot.

CJEU can force national governments to implement and honor EU law, while the ECHR cannot.

CJEU can hear appeals on human rights decisions made by national courts, while the ECHR cannot.

ECHR can enforce human rights laws against governments that fail to implement them, while the CJEU cannot.

26. SCENARIO

Please use the following to answer the next question:

Anna and Frank both work at Granchester University. Anna is a lawyer responsible for data protection, while Frank is a lecturer in the engineering department.

The University maintains a number of types of records:

– Student records, including names, student numbers, home addresses, pre-university information,

university attendance and performance records, details of special educational needs and financial

information.

– Staff records, including autobiographical materials (such as curricula, professional contact files, student evaluations and other relevant teaching files).

– Alumni records, including birthplaces, years of birth, dates of matriculation and conferrals of degrees. These records are available to former students after registering through Granchester’s Alumni portal.

– Department for Education records, showing how certain demographic groups (such as first-generation students) could be expected, on average, to progress. These records do not contain names or identification numbers.

– Under their security policy, the University encrypts all of its personal data records in transit and at rest.

In order to improve his teaching, Frank wants to investigate how his engineering students perform in relational to Department for Education expectations. He has attended one of Anna’s data protection training courses and knows that he should use no more personal data than necessary to accomplish his goal. He creates a program that will only export some student data: previous schools attended, grades originally obtained, grades currently obtained and first time university attended. He wants to keep the records at the individual student level. Mindful of Anna’s training, Frank runs the student numbers through an algorithm to transform them into different reference numbers. He uses the same algorithm on each occasion so that he can update each record over time.

One of Anna’s tasks is to complete the record of processing activities, as required by the GDPR. After receiving her email reminder, as required by the GDPR. After receiving her email reminder, Frank informs Anna about his performance database.

Ann explains to Frank that, as well as minimizing personal data, the University has to check that this new use of existing data is permissible. She also suspects that, under the GDPR, a risk analysis may have to be carried out before the data processing can take place. Anna arranges to discuss this further with Frank after she has done some additional research.

Frank wants to be able to work on his analysis in his spare time, so he transfers it to his home laptop (which is not encrypted). Unfortunately, when Frank takes the laptop into the University he loses it on the train. Frank has to see Anna that day to discuss compatible processing. He knows that he needs to report security incidents, so he decides to tell Anna about his lost laptop at the same time.

Which of the University’s records does Anna NOT have to include in her record of processing activities?

Student records

Staff and alumni records

Frank’s performance database

Department for Education records

27. SCENARIO

Please use the following to answer the next question:

Anna and Frank both work at Granchester University. Anna is a lawyer responsible for data protection, while Frank is a lecturer in the engineering department. The University maintains a number of types of records:

– Student records, including names, student numbers, home addresses, pre-university information, university attendance and performance records, details of special educational needs and financial information.

– Staff records, including autobiographical materials (such as curricula, professional contact files, student evaluations and other relevant teaching files).

– Alumni records, including birthplaces, years of birth, dates of matriculation and conferrals of degrees.

– These records are available to former students after registering through Granchester’s Alumni portal.

Department for Education records, showing how certain demographic groups (such as first-generation students) could be expected, on average, to progress. These records do not contain names or identification numbers.

– Under their security policy, the University encrypts all of its personal data records in transit and at rest.

In order to improve his teaching, Frank wants to investigate how his engineering students perform in relational to Department for Education expectations. He has attended one of Anna’s data protection training courses and knows that he should use no more personal data than necessary to accomplish his goal. He creates a program that will only export some student data: previous schools attended, grades originally obtained, grades currently obtained and first time university attended. He wants to keep the records at the individual student level. Mindful of Anna’s training, Frank runs the student numbers through an algorithm to transform them into different reference numbers. He uses the same algorithm on each occasion so that he can update each record over time.

One of Anna’s tasks is to complete the record of processing activities, as required by the GDPR. After receiving her email reminder, as required by the GDPR. After receiving her email reminder, Frank informs Anna about his performance database.

Ann explains to Frank that, as well as minimizing personal data, the University has to check that this new use of existing data is permissible. She also suspects that, under the GDPR, a risk analysis may have to be carried out before the data processing can take place. Anna arranges to discuss this further with Frank after she has done some additional research.

Frank wants to be able to work on his analysis in his spare time, so he transfers it to his home laptop (which is not encrypted). Unfortunately, when Frank takes the laptop into the University he loses it on the train. Frank has to see Anna that day to discuss compatible processing. He knows that he needs to report security incidents, so he decides to tell Anna about his lost laptop at the same time.

Before Anna determines whether Frank’s performance database is permissible, what additional information does she need?

More information about Frank’s data protection training.

More information about the extent of the information loss.

More information about the algorithm Frank used to mask student numbers.

More information about what students have been told and how the research will be used.

28. SCENARIO

Please use the following to answer the next question:

Anna and Frank both work at Granchester University. Anna is a lawyer responsible for data protection, while Frank is a lecturer in the engineering department. The University maintains a number of types of records:

– Student records, including names, student numbers, home addresses, pre-university information, university attendance and performance records, details of special educational needs and financial information.

– Staff records, including autobiographical materials (such as curricula, professional contact files, student evaluations and other relevant teaching files).

– Alumni records, including birthplaces, years of birth, dates of matriculation and conferrals of degrees.

– These records are available to former students after registering through Granchester’s Alumni portal.

Department for Education records, showing how certain demographic groups (such as first-generation students) could be expected, on average, to progress. These records do not contain names or identification numbers.

– Under their security policy, the University encrypts all of its personal data records in transit and at rest.

In order to improve his teaching, Frank wants to investigate how his engineering students perform in relational to Department for Education expectations. He has attended one of Anna’s data protection training courses and knows that he should use no more personal data than necessary to accomplish his goal. He creates a program that will only export some student data: previous schools attended, grades originally obtained, grades currently obtained and first time university attended. He wants to keep the records at the individual student level. Mindful of Anna’s training, Frank runs the student numbers through an algorithm to transform them into different reference numbers. He uses the same algorithm on each occasion so that he can update each record over time.

One of Anna’s tasks is to complete the record of processing activities, as required by the GDPR. After receiving her email reminder, as required by the GDPR. After receiving her email reminder, Frank informs Anna about his performance database.

Ann explains to Frank that, as well as minimizing personal data, the University has to check that this new use of existing data is permissible. She also suspects that, under the GDPR, a risk analysis may have to be carried out before the data processing can take place. Anna arranges to discuss this further with Frank after she has done some additional research.

Frank wants to be able to work on his analysis in his spare time, so he transfers it to his home laptop (which is not encrypted). Unfortunately, when Frank takes the laptop into the University he loses it on the train. Frank has to see Anna that day to discuss compatible processing. He knows that he needs to report security incidents, so he decides to tell Anna about his lost laptop at the same time.

Anna will find that a risk analysis is NOT necessary in this situation as long as?

The data subjects are no longer current students of Frank’s

The processing will not negatively affect the rights of the data subjects

The algorithms that Frank uses for the processing are technologically sound

The data subjects gave their unambiguous consent for the original processing

29. Which institution has the power to adopt findings that confirm the adequacy of the data protection level in a non-EU country?

The European Parliament

The European Commission

The Article 29 Working Party

The European Council

30. What is true of both the General Data Protection Regulation (GDPR) and the Council of Europe Convention 108?

Both govern international transfers of personal data

Both govern the manual processing of personal data

Both only apply to European Union countries

Both require notification of processing activities to a supervisory authority

31. Which aspect of the GDPR will likely have the most impact on the consistent implementation of data protection laws throughout the European Union?

That it essentially functions as a one-stop shop mechanism

That it takes the form of a Regulation as opposed to a Directive

That it makes notification of large-scale data breaches mandatory

That it makes appointment of a data protection officer mandatory

32. How is the retention of communications traffic data for law enforcement purposes addressed by European data protection law?

The ePrivacy Directive allows individual EU member states to engage in such data retention.

The ePrivacy Directive harmonizes EU member states’ rules concerning such data retention.

The Data Retention Directive’s annulment makes such data retention now permissible.

The GDPR allows the retention of such data for the prevention, investigation, detection or prosecution of criminal offences only.

33. What type of data lies beyond the scope of the General Data Protection Regulation?

Pseudonymized

Anonymized

Encrypted

Masked

34. Under what circumstances would the GDPR apply to personal data that exists in physical form, such as information contained in notebooks or hard copy files?

Only where the personal data is produced as a physical output of specific automated processing activities, such as printing, labelling, or stamping.

Only where the personal data is to be subjected to specific computerized processing, such as image scanning or optical character recognition.

Only where the personal data is treated by automated means in some way, such as computerized distribution or filing.

Only where the personal data is handled in a sufficiently structured manner so as to form part of a filing system.

35. SCENARIO

Please use the following to answer the next question:

You have just been hired by a toy manufacturer based in Hong Kong. The company sells a broad range of dolls, action figures and plush toys that can be found internationally in a wide variety of retail stores. Although the manufacturer has no offices outside Hong Kong and in fact does not employ any staff outside Hong Kong, it has entered into a number of local distribution contracts. The toys produced by the company can be found in all popular toy stores throughout Europe, the United States and Asia. A large portion of the company’s revenue is due to international sales.

The company now wishes to launch a new range of connected toys, ones that can talk and interact with children. The CEO of the company is touting these toys as the next big thing, due to the increased possibilities offered: The figures can answer children’s questions on various subjects, such as mathematical calculations or the weather. Each figure is equipped with a microphone and speaker and can connect to any smartphone or tablet via Bluetooth. Any mobile device within a 10-meter radius can connect to the toys via Bluetooth as well. The figures can also be associated with other figures (from the same manufacturer) and interact with each other for an enhanced play experience.

When a child asks the toy a question, the request is sent to the cloud for analysis, and the answer is generated on cloud servers and sent back to the figure. The answer is given through the figure’s integrated speakers, making it appear as though that the toy is actually responding to the child’s question. The packaging of the toy does not provide technical details on how this works, nor does it mention that this feature requires an internet connection. The necessary data processing for this has been outsourced to a data center located in South Africa. However, your company has not yet revised its consumer-facing privacy policy to indicate this.

In parallel, the company is planning to introduce a new range of game systems through which consumers can play the characters they acquire in the course of playing the game. The system will come bundled with a portal that includes a Near-Field Communications (NFC) reader. This device will read an RFID tag in the action figure, making the figure come to life onscreen. Each character has its own stock features and abilities, but it is also possible to earn additional ones by accomplishing game goals. The only information stored in the tag relates to the figures’ abilities. It is easy to switch characters during the game, and it is possible to bring the figure to locations outside of the home and have the character’s abilities remain intact.

Why is this company obligated to comply with the GDPR?

The company has offices in the E

The company employs staff in the E

The company’s data center is located in a country outside the E

The company’s products are marketed directly to EU customers.

36. SCENARIO

Please use the following to answer the next question:

You have just been hired by a toy manufacturer based in Hong Kong. The company sells a broad range of dolls, action figures and plush toys that can be found internationally in a wide variety of retail stores. Although the manufacturer has no offices outside Hong Kong and in fact does not employ any staff outside Hong Kong, it has entered into a number of local distribution contracts. The toys produced by the company can be found in all popular toy stores throughout Europe, the United States and Asia. A large portion of the company’s revenue is due to international sales.

The company now wishes to launch a new range of connected toys, ones that can talk and interact with children. The CEO of the company is touting these toys as the next big thing, due to the increased possibilities offered: The figures can answer children’s questions on various subjects, such as mathematical calculations or the weather. Each figure is equipped with a microphone and speaker and can connect to any smartphone or tablet via Bluetooth. Any mobile device within a 10-meter radius can

connect to the toys via Bluetooth as well. The figures can also be associated with other figures (from the same manufacturer) and interact with each other for an enhanced play experience.

When a child asks the toy a question, the request is sent to the cloud for analysis, and the answer is generated on cloud servers and sent back to the figure. The answer is given through the figure’s integrated speakers, making it appear as though that the toy is actually responding to the child’s question. The packaging of the toy does not provide technical details on how this works, nor does it mention that this feature requires an internet connection. The necessary data processing for this has been outsourced to a data center located in South Africa. However, your company has not yet revised its consumer-facing privacy policy to indicate this.

In parallel, the company is planning to introduce a new range of game systems through which consumers can play the characters they acquire in the course of playing the game. The system will come bundled with a portal that includes a Near-Field Communications (NFC) reader. This device will read an RFID tag in the action figure, making the figure come to life onscreen. Each character has its own stock features and abilities, but it is also possible to earn additional ones by accomplishing game goals. The only information stored in the tag relates to the figures’ abilities. It is easy to switch characters during the game, and it is possible to bring the figure to locations outside of the home and have the character’s abilities remain intact.

What presents the BIGGEST potential privacy issue with the company’s practices?

The NFC portal can read any data stored in the action figures

The information about the data processing involved has not been specified

The cloud service provider is in a country that has not been deemed adequate

The RFID tag in the action figures has the potential for misuse because of the toy’s evolving capabilities

37. SCENARIO

Please use the following to answer the next question:

You have just been hired by a toy manufacturer based in Hong Kong. The company sells a broad range of dolls, action figures and plush toys that can be found internationally in a wide variety of retail stores. Although the manufacturer has no offices outside Hong Kong and in fact does not employ any staff outside Hong Kong, it has entered into a number of local distribution contracts. The toys produced by the company can be found in all popular toy stores throughout Europe, the United States and Asia. A large portion of the company’s revenue is due to international sales.

The company now wishes to launch a new range of connected toys, ones that can talk and interact with children. The CEO of the company is touting these toys as the next big thing, due to the increased possibilities offered: The figures can answer children’s questions on various subjects, such as mathematical calculations or the weather. Each figure is equipped with a microphone and speaker and can connect to any smartphone or tablet via Bluetooth. Any mobile device within a 10-meter radius can connect to the toys via Bluetooth as well. The figures can also be associated with other figures (from the same manufacturer) and interact with each other for an enhanced play experience.

When a child asks the toy a question, the request is sent to the cloud for analysis, and the answer is generated on cloud servers and sent back to the figure. The answer is given through the figure’s integrated speakers, making it appear as though that the toy is actually responding to the child’s question. The packaging of the toy does not provide technical details on how this works, nor does it mention that this feature requires an internet connection. The necessary data processing for this has been outsourced to a data center located in South Africa. However, your company has not yet revised its consumer-facing privacy policy to indicate this.

In parallel, the company is planning to introduce a new range of game systems through which consumers can play the characters they acquire in the course of playing the game. The system will come bundled with a portal that includes a Near-Field Communications (NFC) reader. This device will read an RFID tag in the action figure, making the figure come to life onscreen. Each character has its own stock features and abilities, but it is also possible to earn additional ones by accomplishing game goals. The only information stored in the tag relates to the figures’ abilities. It is easy to switch characters during the game, and it is possible to bring the figure to locations outside of the home and have the character’s abilities remain intact.

To ensure GDPR compliance, what should be the company’s position on the issue of consent?

The child, as the user of the action figure, can provide consent himself, as long as no information is shared for marketing purposes.

Written authorization attesting to the responsible use of children’s data would need to be obtained from the supervisory authority.

Consent for data collection is implied through the parent’s purchase of the action figure for the child.

Parental consent for a child’s use of the action figures would have to be obtained before any data could be collected.

38. SCENARIO

Please use the following to answer the next question:

You have just been hired by a toy manufacturer based in Hong Kong. The company sells a broad range of dolls, action figures and plush toys that can be found internationally in a wide variety of retail stores. Although the manufacturer has no offices outside Hong Kong and in fact does not employ any staff outside Hong Kong, it has entered into a number of local distribution contracts. The toys produced by the company can be found in all popular toy stores throughout Europe, the United States and Asia. A large portion of the company’s revenue is due to international sales.

The company now wishes to launch a new range of connected toys, ones that can talk and interact with children. The CEO of the company is touting these toys as the next big thing, due to the increased possibilities offered: The figures can answer children’s questions on various subjects, such as mathematical calculations or the weather. Each figure is equipped with a microphone and speaker and can connect to any smartphone or tablet via Bluetooth. Any mobile device within a 10-meter radius can connect to the toys via Bluetooth as well. The figures can also be associated with other figures (from the same manufacturer) and interact with each other for an enhanced play experience.

When a child asks the toy a question, the request is sent to the cloud for analysis, and the answer is generated on cloud servers and sent back to the figure. The answer is given through the figure’s integrated speakers, making it appear as though that the toy is actually responding to the child’s question. The packaging of the toy does not provide technical details on how this works, nor does it mention that this feature requires an internet connection. The necessary data processing for this has been outsourced to a data center located in South Africa. However, your company has not yet revised its consumer-facing privacy policy to indicate this.

In parallel, the company is planning to introduce a new range of game systems through which consumers can play the characters they acquire in the course of playing the game. The system will come bundled with a portal that includes a Near-Field Communications (NFC) reader. This device will read an RFID tag in the action figure, making the figure come to life onscreen. Each character has its own stock features and abilities, but it is also possible to earn additional ones by accomplishing game goals. The only information stored in the tag relates to the figures’ abilities. It is easy to switch characters during the game, and it is possible to bring the figure to locations outside of the home and have the character’s abilities remain intact.

In light of the requirements of Article 32 of the GDPR (related to the Security of Processing), which practice should the company institute?

Encrypt the data in transit over the wireless Bluetooth connection.

Include dual-factor authentication before each use by a child in order to ensure a minimum amount of security.

Include three-factor authentication before each use by a child in order to ensure the best level of security possible.

Insert contractual clauses into the contract between the toy manufacturer and the cloud service provider, since South Africa is outside the European Union.

39. Which of the following would most likely NOT be covered by the definition of “personal data” under the GDPR?

The payment card number of a Dutch citizen

The

social security number of an American citizen living in France

The unlinked aggregated data used for statistical purposes by an Italian company

The identification number of a German candidate for a professional examination in Germany

40. Which of the following would MOST likely trigger the extraterritorial effect of the GDPR, as specified by Article 3?

The behavior of suspected terrorists being monitored by EU law enforcement bodies.

Personal data of EU citizens being processed by a controller or processor based outside the E

The behavior of EU citizens outside the EU being monitored by non-EU law enforcement bodies.

Personal data of EU residents being processed by a non-EU business that targets EU customers.

41. How does the GDPR now define “processing”?

Any act involving the collecting and recording of personal data.

Any operation or set of operations performed on personal data or on sets of personal data.

Any use or disclosure of personal data compatible with the purpose for which the data was collected.

Any operation or set of operations performed by automated means on personal data or on sets of personal data.

42. What is the consequence if a processor makes an independent decision regarding the purposes and means of processing it carries out on behalf of a controller?

The controller will be liable to pay an administrative fine

The processor will be liable to pay compensation to affected data subjects

The processor will be considered to be a controller in respect of the processing concerned

The controller will be required to demonstrate that the unauthorized processing negatively affected one or more of the parties involved

43. According to the GDPR, how is pseudonymous personal data defined?

Data that can no longer be attributed to a specific data subject without the use of additional information kept separately.

Data that can no longer be attributed to a specific data subject, with no possibility of re-identifying the data.

Data that has been rendered anonymous in such a manner that the data subject is no longer identifiable.

Data that has been encrypted or is subject to other technical safeguards.

44. Under which of the following conditions does the General Data Protection Regulation NOT apply to the processing of personal data?

When the personal data is processed only in non-electronic form

When the personal data is collected and then pseudonymised by the controller

When the personal data is held by the controller but not processed for further purposes

When the personal data is processed by an individual only for their household activities

45. According to the E-Commerce Directive 2000/31/EC, where is the place of “establishment” for a company providing services via an Internet website confirmed by the GDPR?

Where the technology supporting the website is located

Where the website is accessed

Where the decisions about processing are made

Where the customer’s Internet service provider is located

46. SCENARIO

Please use the following to answer the next question:

Louis, a long-time customer of Bedrock Insurance, was involved in a minor car accident a few months ago. Although no one was hurt, Louis has been plagued by texts and calls from a company called Accidentable offering to help him recover compensation for personal injury. Louis has heard about insurance companies selling customers’ data to third parties, and he’s convinced that Accidentable must have gotten his information from Bedrock Insurance.

Louis has also been receiving an increased amount of marketing information from Bedrock, trying to sell him their full range of their insurance policies.

Perturbed by this, Louis has started looking at price comparison sites on the internet and has been shocked to find that other insurers offer much cheaper rates than Bedrock, even though he has been a loyal customer for many years. When his Bedrock policy comes up for renewal, he decides to switch to Zantrum Insurance.

In order to activate his new insurance policy, Louis needs to supply Zantrum with information about his No Claims bonus, his vehicle and his driving history. After researching his rights under the GDPR, he writes to ask Bedrock to transfer his information directly to Zantrum. He also takes this opportunity to ask Bedrock to stop using his personal data for marketing purposes.

Bedrock supplies Louis with a PDF and XML (Extensible Markup Language) versions of his No Claims Certificate, but tells Louis it cannot transfer his data directly to Zantrum as this is not technically feasible. Bedrock also explains that Louis’s contract included a provision whereby Louis agreed that his data could be used for marketing purposes; according to Bedrock, it is too late for Louis to change his mind about this. It angers Louis when he recalls the wording of the contract, which was filled with legal jargon and very confusing.

In the meantime, Louis is still receiving unwanted calls from Accidentable Insurance. He writes to Accidentable to ask for the name of the organization that supplied his details to them. He warns Accidentable that he plans to complain to the data protection authority, because he thinks their company has been using his data unlawfully. His letter states that he does not want his data being used by them in any way.

Accidentable’s response letter confirms Louis’s suspicions. Accidentable is Bedrock Insurance’s wholly owned subsidiary, and they received information about Louis’s accident from Bedrock shortly after Louis submitted his accident claim. Accidentable assures Louis that there has been no breach of the GDPR, as Louis’s contract included, a provision in which he agreed to share his information with Bedrock’s affiliates for business purposes.

Louis is disgusted by the way in which he has been treated by Bedrock, and writes to them insisting that all his information be erased from their computer system.

Which statement accurately summarizes Bedrock’s obligation in regard to Louis’s data portability request?

Bedrock does not have a duty to transfer Louis’s data to Zantrum if doing so is legitimately not technically feasible.

Bedrock does not have to transfer Louis’s data to Zantrum because the right to data portability does not apply where personal data are processed in order to carry out tasks in the public interest.

Bedrock has failed to comply with the duty to transfer Louis’s data to Zantrum because the duty applies wherever personal data are processed by automated means and necessary for the performance of a contract with the customer.

Bedrock has failed to comply with the duty to transfer Louis’s data to Zantrum because it has an obligation to develop commonly used, machine-readable and interoperable formats so that all customer data can be ported to other insurers on request.

47. SCENARIO

Please use the following to answer the next question:

Louis, a long-time customer of Bedrock Insurance, was involved in a minor car accident a few months ago. Although no one was hurt, Louis has been plagued by texts and calls from a company called Accidentable offering to help him recover compensation for personal injury. Louis has heard about insurance companies selling customers’ data to third parties, and he’s convinced that Accidentable must have gotten his information from Bedrock Insurance.

Louis has also been receiving an increased amount of marketing information from Bedrock, trying to sell him their full range of their insurance policies.

Perturbed by this, Louis has started looking at price comparison sites on the internet and has been shocked to find that other insurers offer much cheaper rates than Bedrock, even though he has been a loyal customer for many years. When his Bedrock policy comes up for renewal, he decides to switch to Zantrum Insurance.

In order to activate his new insurance policy, Louis needs to supply Zantrum with information about his No Claims bonus, his vehicle and his driving history. After researching his rights under the GDPR, he writes to ask Bedrock to transfer his information directly to Zantrum. He also takes this opportunity to ask Bedrock to stop using his personal data for marketing purposes.

Bedrock supplies Louis with a PDF and XML (Extensible Markup Language) versions of his No Claims Certificate, but tells Louis it cannot transfer his data directly to Zantrum as this is not technically feasible. Bedrock also explains that Louis’s contract included a provision whereby Louis agreed that his data could be used for marketing purposes; according to Bedrock, it is too late for Louis to change his mind about this. It angers Louis when he recalls the wording of the contract, which was filled with legal jargon and very confusing.

In the meantime, Louis is still receiving unwanted calls from Accidentable Insurance. He writes to Accidentable to ask for the name of the organization that supplied his details to them. He warns Accidentable that he plans to complain to the data protection authority, because he thinks their company has been using his data unlawfully. His letter states that he does not want his data being used by them in any way.

Accidentable’s response letter confirms Louis’s suspicions. Accidentable is Bedrock Insurance’s wholly owned subsidiary, and they received information about Louis’s accident from Bedrock shortly after Louis submitted his accident claim. Accidentable assures Louis that there has been no breach of the GDPR, as Louis’s contract included, a provision in which he agreed to share his information with Bedrock’s affiliates for business purposes.

Louis is disgusted by the way in which he has been treated by Bedrock, and writes to them insisting that all

his information be erased from their computer system.

After Louis has exercised his right to restrict the use of his data, under what conditions would Accidentable have grounds for refusing to comply?

If Accidentable is entitled to use of the data as an affiliate of Bedrock.

If Accidentable also uses the data to conduct public health research.

If the data becomes necessary to defend Accidentable’s legal rights.

If the accuracy of the data is not an aspect that Louis is disputing.

48. Under the GDPR, who would be LEAST likely to be allowed to engage in the collection, use, and disclosure of a data subject’s sensitive medical information without the data subject’s knowledge or consent?

A member of the judiciary involved in adjudicating a legal dispute involving the data subject and concerning the health of the data subject.

A public authority responsible for public health, where the sharing of such information is considered necessary for the protection of the general populace.

A health professional involved in the medical care for the data subject, where the data subject’s life hinges on the timely dissemination of such information.

A journalist writing an article relating to the medical condition in question, who believes that the publication of such information is in the public interest.

49. With the issue of consent, the GDPR allows member states some choice regarding what?

The mechanisms through which consent may be communicated

The circumstances in which silence or inactivity may constitute consent

The age at which children must be required to obtain parental consent

The timeframe in which data subjects are allowed to withdraw their consent

50. Which sentence BEST summarizes the concepts of “fairness,” “lawfulness” and “transparency”, as expressly required by Article 5 of the GDPR?

Fairness and transparency refer to the communication of key information before collecting data; lawfulness refers to compliance with government regulations.

Fairness refers to limiting the amount of data collected from individuals; lawfulness refers to the approval of company guidelines by the state; transparency solely relates to communication of key information before collecting data.

Fairness refers to the security of personal data; lawfulness and transparency refers to the analysis of ordinances to ensure they are uniformly enforced.

Fairness refers to the collection of data from diverse subjects; lawfulness refers to the need for legal rules to be uniform; transparency refers to giving individuals access to their data.

51. Article 5(1)(b) of the GDPR states that personal data must be “collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes.” Based on Article 5(1)(b), what is the impact of a member state’s interpretation of the word “incompatible”?

It dictates the level of security a processor must follow when using and storing personal data for two different purposes.

It guides the courts on the severity of the consequences for those who are convicted of the intentional misuse of personal data.

It sets the standard for the level of detail a controller must record when documenting the purpose for collecting personal data.

It indicates the degree of flexibility a controller has in using personal data in ways that may vary from its original intended purpose.

52. Tanya is the Data Protection Officer for Curtains Inc., a GDPR data controller. She has recommended that the company encrypt all personal data at rest.

Which GDPR principle is she following?

Accuracy

Storage Limitation

Integrity and confidentiality

Lawfulness, fairness and transparency

53. A well-known video production company, based in Spain but specializing in documentaries filmed worldwide, has just finished recording several hours of footage featuring senior citizens in the streets of Madrid. Under what condition would the company NOT be required to obtain the consent of everyone whose image they use for their documentary?

If obtaining consent is deemed to involve disproportionate effort.

If obtaining consent is deemed voluntary by local legislation.

If the company limits the footage to data subjects solely of legal age.

If the company’s status as a documentary provider allows it to claim legitimate interest.

54. A Spanish electricity customer calls her local supplier with questions about the company’s upcoming merger. Specifically, the customer wants to know the recipients to whom her personal data will be disclosed once the merger is final. According to Article 13 of the GDPR, what must the company do before providing the customer with the requested information?

Verify that the request is applicable to the data collected before the GDPR entered into force.

Verify that the purpose of the request from the customer is in line with the GDP

Verify that the personal data has not already been sent to the customer.

Verify that the identity of the customer can be proven by other means.

55. Under the GDPR, where personal data is not obtained directly from the data subject, a controller is exempt from directly providing information about processing to the data subject if?

The data subject already has information regarding how his data will be used

The provision of such information to the data subject would be too problematic

Third-party data would be disclosed by providing such information to the data subject

The processing of the data subject’s data is protected by appropriate technical measures

56. SCENARIO

Please use the following to answer the next question:

Due to rapidly expanding workforce, Company A has decided to outsource its payroll function to Company B. Company B is an established payroll service provider with a sizable client base and a solid reputation in the industry.

Company B’s payroll solution for Company A relies on the collection of time and attendance data obtained via a biometric entry system installed in each of Company A’s factories. Company B won’t hold any biometric data itself, but the related data will be uploaded to Company B’s UK servers and used to provide the payroll service.

Company B ’ s live systems will contain the following information for each of Company A ’ s employees:

– Name

– Address

– Date of Birth

– Payroll number

– National Insurance number

– Sick pay entitlement

– Maternity/paternity pay entitlement

– Holiday entitlement

– Pension and benefits contributions

– Trade union contributions

Jenny is the compliance officer at Company A. She first considers whether Company A needs to carry out a data protection impact assessment in relation to the new time and attendance system, but isn’t sure whether or not this is required.

Jenny does know, however, that under the GDPR there must be a formal written agreement requiring Company B to use the time and attendance data only for the purpose of providing the payroll service, and to apply appropriate technical and organizational security measures for safeguarding the data. Jenny suggests that Company B obtain advice from its data protection officer. The company doesn’t have a DPO but agrees, in the interest of finalizing the contract, to sign up for the provisions in full. Company A enters into the contract.

Weeks later, while still under contract with Company A, Company B embarks upon a separate project meant to enhance the functionality of its payroll service, and engages Company C to help. Company C agrees to extract all personal data from Company B’s live systems in order to create a new database for Company B. This database will be stored in a test environment hosted on Company C’s U.S. server. The two companies agree not to include any data processing provisions in their services agreement, as data is only being used for IT testing purposes.

Unfortunately, Company C’s U.S. server is only protected by an outdated IT security system, and suffers a cyber security incident soon after Company C begins work on the project. As a result, data relating to Company A’s employees is visible to anyone visiting Company C’s website. Company A is unaware of this until Jenny receives a letter from the supervisory authority in connection with the investigation that ensues. As soon as Jenny is made aware of the breach, she notifies all affected employees.

Under the GDPR, which of Company B’s actions would NOT be likely to trigger a potential enforcement action?

Their omission of data protection provisions in their contract with Company

Their failure to provide sufficient security safeguards to Company A’s data.

Their engagement of Company C to improve their payroll service.

Their decision to operate without a data protection officer.

57. SCENARIO

Please use the following to answer the next question:

Due to rapidly expanding workforce, Company A has decided to outsource its payroll function to Company B. Company B is an established payroll service provider with a sizable client base and a solid reputation in the industry.

Company B’s payroll solution for Company A relies on the collection of time and attendance data obtained via a biometric entry system installed in each of Company A’s factories. Company B won’t hold any biometric data itself, but the related data will be uploaded to Company B’s UK servers and used to provide the payroll service.

Company B’s live systems will contain the following information for each of Company A’s employees:

– Name

– Address

– Date of Birth

– Payroll number

– National Insurance number

– Sick pay entitlement

– Maternity/paternity pay entitlement

– Holiday entitlement

– Pension and benefits contributions

– Trade union contributions

Jenny is the compliance officer at Company A. She first considers whether Company A needs to carry out a data protection impact assessment in relation to the new time and attendance system, but isn’t sure whether or not this is required.

Jenny does know, however, that under the GDPR there must be a formal written agreement requiring Company B to use the time and attendance data only for the purpose of providing the payroll service, and to apply appropriate technical and organizational security measures for safeguarding the data. Jenny suggests that Company B obtain advice from its data protection officer. The company doesn’t have a DPO but agrees, in the interest of finalizing the contract, to sign up for the provisions in full. Company A enters into the contract.

Weeks later, while still under contract with Company A, Company B embarks upon a separate project meant to enhance the functionality of its payroll service, and engages Company C to help. Company C agrees to extract all personal data from Company B’s live systems in order to create a new database for Company B. This database will be stored in a test environment hosted on Company C’s U.S. server. The two companies agree not to include any data processing provisions in their services agreement, as data is only being used for IT testing purposes.

Unfortunately, Company C’s U.S. server is only protected by an outdated IT security system, and suffers a cyber security incident soon after Company C begins work on the project. As a result, data relating to Company A’s employees is visible to anyone visiting Company C’s website. Company A is unaware of this until Jenny receives a letter from the supervisory authority in connection with the investigation that ensues. As soon as Jenny is made aware of the breach, she notifies all affected employees.

The GDPR requires sufficient guarantees of a company’s ability to implement adequate technical and organizational measures.

What would be the most realistic way that Company B could have fulfilled this requirement?

Hiring companies whose measures are consistent with recommendations of accrediting bodies.

Requesting advice and technical support from Company A’s IT team.

Avoiding the use of another company’s data to improve their own services.

Vetting companies’ measures with the appropriate supervisory authority.

58. In 2016’s Guidance, the United Kingdom’s Information Commissioner’s Office (ICO) reaffirmed the importance of using a “layered notice” to provide data subjects with what?

A privacy notice containing brief information whilst offering access to further detail.

A privacy notice explaining the consequences for opting out of the use of cookies on a website.

An explanation of the security measures used when personal data is transferred to a third party.

An efficient means of providing written consent in member states where they are required to do so.

59. When collecting personal data in a European Union (EU) member state, what must a company do if it collects personal data from a source other than the data subjects themselves?

Inform the subjects about the collection

Provide a public notice regarding the data

Upgrade security to match that of the source

Update the data within a reasonable timeframe

60. Under the GDPR, which essential pieces of information must be provided to data subjects before collecting their personal data?

The authority by which the controller is collecting the data and the third parties to whom the data will be sent.

The name/s of relevant government agencies involved and the steps needed for revising the data.

The identity and contact details of the controller and the reasons the data is being collected.

The contact information of the controller and a description of the retention policy.

61. Assuming that the “without undue delay” provision is followed, what is the time limit for complying with a data access request?

Within 40 days of receipt

Within 40 days of receipt, which may be extended by up to 40 additional days

Within one month of receipt, which may be extended by up to an additional month

Within one month of receipt, which may be extended by an additional two months

62. A U.S.-based online shop uses sophisticated software to track the browsing behavior of its European customers and predict future purchases. It also shares this information with third parties. Under the GDPR,

what is the online shop’s PRIMARY obligation while engaging in this kind of profiling?

It must solicit informed consent through a notice on its website

It must seek authorization from the European supervisory authorities

It must be able to demonstrate a prior business relationship with the customers

It must prove that it uses sufficient security safeguards to protect customer data

63. Which of the following would NOT be relevant when determining if a processing activity would be considered profiling?

If the processing is to be performed by a third-party vendor

If the processing involves data that is considered personal data

If the processing of the data is done through automated means

If the processing is used to predict the behavior of data subjects

64. Under Article 21 of the GDPR, a controller must stop profiling when requested by a data subject, unless it can demonstrate compelling legitimate grounds that override the interests of the individual.

In the Guidelines on Automated individual decision-making and Profiling, the WP 29 says the controller needs to do all of the following to demonstrate that it has such legitimate grounds EXCEPT?

Carry out an exercise that weighs the interests of the controller and the basis for the data subject’s objection.

Consider the impact of the profiling on the data subject’s interest, rights and freedoms.

Demonstrate that the profiling is for the purposes of direct marketing.

Consider the importance of the profiling to their particular objective.

65. SCENARIO

Please use the following to answer the next question:

TripBliss Inc. is a travel service company which has lost substantial revenue over the last few years. Their new manager, Oliver, suspects that this is partly due to the company’s outdated website. After doing some research, he meets with a sales representative from the up-and-coming IT company Techiva, hoping that they can design a new, cutting-edge website for TripBliss Inc.’s foundering business.

During negotiations, a Techiva representative describes a plan for gathering more customer information

through detailed questionnaires, which could be used to tailor their preferences to specific travel destinations. TripBliss Inc. can choose any number of data categories C age, income, ethnicity C that would help them best accomplish their goals. Oliver loves this idea, but would also like to have some way of gauging how successful this approach is, especially since the questionnaires will require customers to provide explicit consent to having their data collected. The Techiva representative suggests that they also run a program to analyze the new website’s traffic, in order to get a better understanding of how customers are using it. He explains his plan to place a number of cookies on customer devices. The cookies will allow the company to collect IP addresses and other information, such as the sites from which the customers came, how much time they spend on the TripBliss Inc. website, and which pages on the site they visit. All of this information will be compiled in log files, which Techiva will analyze by means of a special program. TripBliss Inc. would receive aggregate statistics to help them evaluate the website’s effectiveness. Oliver enthusiastically engages Techiva for these services.

Techiva assigns the analytics portion of the project to longtime account manager Leon Santos. As is standard practice, Leon is given administrator rights to TripBliss Inc.’s website, and can authorize access to the log files gathered from it. Unfortunately for TripBliss Inc., however, Leon is taking on this new project at a time when his dissatisfaction with Techiva is at a high point. In order to take revenge for what he feels has been unfair treatment at the hands of the company, Leon asks his friend Fred, a hobby hacker, for help. Together they come up with the following plan: Fred will hack into Techiva’s system and copy their log files onto a USB stick. Despite his initial intention to send the USB to the press and to the data protection authority in order to denounce Techiva, Leon experiences a crisis of conscience and ends up reconsidering his plan. He decides instead to securely wipe all the data from the USB stick and inform his manager that the company’s system of access control must be reconsidered.

If TripBliss Inc. decides not to report the incident to the supervisory authority, what would be their BEST defense?

The resulting obligation to notify data subjects would involve disproportionate effort.

The incident resulted from the actions of a third-party that were beyond their control.

The destruction of the stolen data makes any risk to the affected data subjects unlikely.

The sensitivity of the categories of data involved in the incident was not substantial enough.

66. SCENARIO

Please use the following to answer the next question:

TripBliss Inc. is a travel service company which has lost substantial revenue over the last few years. Their new manager, Oliver, suspects that this is partly due to the company’s outdated website. After doing some research, he meets with a sales representative from the up-and-coming IT company Techiva, hoping that they can design a new, cutting-edge website for TripBliss Inc.’s foundering business.

During negotiations, a Techiva representative describes a plan for gathering more customer information through detailed questionnaires, which could be used to tailor their preferences to specific travel destinations. TripBliss Inc. can choose any number of data categories C age, income, ethnicity C that would help them best accomplish their goals. Oliver loves this idea, but would also like to have some way of gauging how successful this approach is, especially since the questionnaires will require customers to provide explicit consent to having their data collected. The Techiva representative suggests that they also run a program to analyze the new website’s traffic, in order to get a better understanding of how customers are using it. He explains his plan to place a number of cookies on customer devices. The cookies will allow the company to collect IP addresses and other information, such as the sites from which the customers came, how much time they spend on the TripBliss Inc. website, and which pages on the site they visit. All of this information will be compiled in log files, which Techiva will analyze by means of a special program. TripBliss Inc. would receive aggregate statistics to help them evaluate the website’s effectiveness. Oliver enthusiastically engages Techiva for these services.

Techiva assigns the analytics portion of the project to longtime account manager Leon Santos. As is standard practice, Leon is given administrator rights to TripBliss Inc.’s website, and can authorize access to the log files gathered from it. Unfortunately for TripBliss Inc., however, Leon is taking on this new project at a time when his dissatisfaction with Techiva is at a high point. In order to take revenge for what he feels has been unfair treatment at the hands of the company, Leon asks his friend Fred, a hobby hacker, for help. Together they come up with the following plan: Fred will hack into Techiva’s system and copy their log files onto a USB stick. Despite his initial intention to send the USB to the press and to the data protection authority in order to denounce Techiva, Leon experiences a crisis of conscience and ends up reconsidering his plan. He decides instead to securely wipe all the data from the USB stick and inform his manager that the company’s system of access control must be reconsidered.

With regard to TripBliss Inc.’s use of website cookies, which of the following statements is correct?

Because not all of the cookies are strictly necessary to enable the use of a service requested from TripBliss Inc., consent requirements apply to their use of cookies.

Because of the categories of data involved, explicit consent for the use of cookies must be obtained separately from customers.

Because Techiva will receive only aggregate statistics of data collected from the cookies, no additional consent is necessary.

Because the use of cookies involves the potential for location tracking, explicit consent must be obtained from customers.

67. Company X has entrusted the processing of their payroll data to Provider Y. Provider Y stores this encrypted data on its server. The IT department of Provider Y finds out that someone managed to hack into the system and take a copy of the data from its server.

In this scenario, whom does Provider Y have the obligation to notify?

The public

Company X

Law enforcement

The supervisory authority

68. When hiring a data processor, which action would a data controller NOT be able to depend upon to avoid liability in the event of a security breach?

Documenting due diligence steps taken in the pre-contractual stage.

Conducting a risk assessment to analyze possible outsourcing threats.

Requiring that the processor directly notify the appropriate supervisory authority.

Maintaining evidence that the processor was the best possible market choice available.

69. WP29’s “Guidelines on Personal data breach notification under Regulation 2016/679’’ provides examples of ways to communicate data breaches transparently.

Which of the following was listed as a method that would NOT be effective for communicating a breach to data subjects?

A postal notification

A direct electronic message

A notice on a corporate blog

A prominent advertisement in print media

70. Which of the following would require designating a data protection officer?

Processing is carried out by an organization employing 250 persons or more.

Processing is carried out for the purpose of providing for-profit goods or services to individuals in the E

The core activities of the controller or processor consist of processing operations of financial information or information relating to children.

The core activities of the controller or processor consist of processing operations that require systematic monitoring of data subjects on a large scale.

CIPP-E Exam Questions – Certified Information Privacy Professional/Europe (CIPP/E)

CIPP-E Exam Questions – Certified Information Privacy Professional/Europe (CIPP/E)

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