Download IAPP CIPP-E Exam Dumps to Pass Exam Easily in 2026 [Q142-Q166]

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Download IAPP CIPP-E Exam Dumps to Pass Exam Easily in 2026

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NEW QUESTION # 142
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"?

  • A. It dictates the level of security a processor must follow when using and storing personal data for two different purposes.
  • B. It indicates the degree of flexibility a controller has in using personal data in ways that may vary from its original intended purpose.
  • C. It guides the courts on the severity of the consequences for those who are convicted of the intentional misuse of personal data.
  • D. It sets the standard for the level of detail a controller must record when documenting the purpose for collecting personal data.

Answer: B

Explanation:
The purpose limitation principle requires that personal data be collected for specified, explicit and legitimate purposes and not be further processed in a manner that is incompatible with those purposes. However, the GDPR does not provide a clear definition of what constitutes an incompatible purpose. Instead, it leaves room for interpretation by the member states, taking into account the context and circumstances of the processing. This means that the degree of flexibility a controller has in using personal data for a new purpose may vary depending on the member state's law and guidance. Some factors that may affect the compatibility assessment include the link between the original and the new purpose, the expectations of the data subject, the nature of the data, the impact of the further processing, and the safeguards applied by the controller. Reference:
GDPR Article 5(1)(b), which states the purpose limitation principle.
GDPR Article 6(4), which lists the criteria for assessing the compatibility of a new purpose.
ICO guidance, which explains the purpose limitation principle and provides examples of compatible and incompatible purposes.
[EDPB guidelines], which provide further guidance on the application of the purpose limitation principle.


NEW QUESTION # 143
How is the retention of communications traffic data for law enforcement purposes addressed by European data protection law?

  • A. The Data Retention Directive's annulment makes such data retention now permissible.
  • B. The ePrivacy Directive harmonizes EU member states' rules concerning such data retention.
  • C. The ePrivacy Directive allows individual EU member states to engage in such data retention.
  • D. The GDPR allows the retention of such data for the prevention, investigation, detection or prosecution of criminal offences only.

Answer: B

Explanation:
The ePrivacy Directive is a European Union (EU) directive that aims to protect the confidentiality of electronic communications and prevent their indiscriminate interception or monitoring. It was adopted in 2002 and amended in 2009. It applies to all providers of electronic communication services, such as internet service providers, mobile network operators, and online platforms12.
One of the main objectives of the ePrivacy Directive is to ensure that the retention of communications traffic data for law enforcement purposes is subject to strict conditions and safeguards. Communications traffic data refers to any information relating to the transmission or routing of electronic communications, such as IP addresses, timestamps, and metadata3. Such data can be used by competent national authorities for the prevention, investigation, detection or prosecution of criminal offences and safeguarding national security4.
However, the ePrivacy Directive does not allow individual EU member states to engage in such data retention without harmonizing their rules. Article 6(1)(b) of the directive states that "Member States shall ensure that any measures taken by them in relation to the retention of traffic data are consistent with this Directive". Therefore, each EU member state must adopt a national law that complies with the requirements and limitations set by the directive12.
The Data Retention Directive (DRD) was a previous EU directive that aimed to establish a common framework for the retention of communications traffic data for law enforcement purposes across all EU member states. It was adopted in 2006 and amended in 2010. However, it was annulled by the Court of Justice of the European Union (CJEU) in 2014 on procedural grounds. The CJEU found that some provisions of the DRD were inconsistent with other EU directives and principles, such as Article 8(2) of the Charter of Fundamental Rights (CFR), which protects individuals from arbitrary interference with their privacy56.
The GDPR is a new EU regulation that implements some aspects of the DRD into national law through its provisions on processing personal data. However, it does not address directly the issue of communications traffic data retention for law enforcement purposes. Instead, it requires providers to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk involved in processing personal data. These measures include encryption, pseudonymisation, access control, and accountability7 . The GDPR also grants individuals certain rights regarding their personal data, such as access, rectification, erasure, portability, and objection7 .
Therefore, under current EU law, there is no single legal basis for retaining communications traffic data for law enforcement purposes across all EU member states. Each member state must adopt its own national law that respects the principles and limitations established by the ePrivacy Directive.
References:
ePrivacy Directive
ePrivacy Regulation
What is Communications Traffic Data?
How is Communications Traffic Data Retained?
Data Retention Directive
Data Retention Directive annulled by CJEU
General Data Protection Regulation
What are your rights regarding your personal data?
Reference: https://www.law.kuleuven.be/citip/en/archive/copy_of_publications/440retention-of-traffic-data- dumortier-goemans2f90.pdf (9)


NEW QUESTION # 144
What term BEST describes the European model for data protection?

  • A. Sectoral
  • B. Comprehensive
  • C. Self-regulatory
  • D. Market-based

Answer: B

Explanation:
The European model for data protection is best described as comprehensive, because it covers all sectors and types of data processing, and applies to any organization that targets or collects data related to people in the EU. The GDPR is the main legal instrument of this model, and it establishes a set of principles, rights, and obligations for data protection, as well as a harmonized framework for enforcement and cooperation among EU member states and data protection authorities. The GDPR also aims to ensure consistency with other EU laws and policies, such as the ePrivacy Directive, the Charter of Fundamental Rights, and the European Data Strategy. The European model for data protection is based on the recognition of data protection as a fundamental right and a public interest, and it reflects the EU's values and objectives of promoting human dignity, democracy, and the rule of law. References:
* Data protection in the EU, section "Legislation"
* What is GDPR, the EU's new data protection law?, section "What is the GDPR?"
* European Data Protection, Third Edition, page 1, section "Introduction"
* European Data Protection: Law and Practice, page 1, section "Introduction"


NEW QUESTION # 145
Which of the following is NOT recognized as being a common characteristic of cloud-computing services?

  • A. The service's infrastructure is shared among the supplier's customers and can be located in a number of countries.
  • B. The supplier allows customer data to be transferred around the infrastructure according to capacity.
  • C. The supplier assumes the vendor's business risk associated with data processed by the supplier.
  • D. The supplier determines the location, security measures, and service standards applicable to the processing.

Answer: C

Explanation:
This is not a common characteristic of cloud-computing services, as the supplier usually does not assume the vendor's business risk. In fact, the supplier often limits its liability for data breaches or losses, and the vendor remains responsible for complying with data protection laws and regulations. The other options are common characteristics of cloud-computing services, as they reflect the nature of cloud computing as a flexible, scalable, and cost-effective way of processing data, but also pose challenges for data protection and security. Reference:
Free CIPP/E Study Guide, page 17, section 2.3.2
CIPP/E Certification, page 12, section 2.3.2
Cipp-e Study guides, Class notes & Summaries, page 23, section 2.3.2


NEW QUESTION # 146
SCENARIO
Please use the following to answer the next question:
Gentle Hedgehog Inc. is a privately owned website design agency incorporated in Italy. The company has numerous remote workers in different EU countries. Recently, the management of Gentle Hedgehog noticed a decrease in productivity of their sales team, especially among remote workers. As a result, the company plans to implement a robust but privacy-friendly remote surveillance system to prevent absenteeism, reward top performers, and ensure the best quality of customer service when sales people are interacting with customers.
Gentle Hedgehog eventually hires Sauron Eye Inc., a Chinese vendor of employee surveillance software whose European headquarters is in Germany. Sauron Eye's software provides powerful remote-monitoring capabilities, including 24/7 access to computer cameras and microphones, screen captures, emails, website history, and keystrokes. Any device can be remotely monitored from a central server that is securely installed at Gentle Hedgehog headquarters. The monitoring is invisible by default; however, a so-called Transparent Mode, which regularly and conspicuously notifies all users about the monitoring and its precise scope, also exists. Additionally, the monitored employees are required to use a built-in verification technology involving facial recognition each time they log in.
All monitoring data, including the facial recognition data, is securely stored in Microsoft Azure cloud servers operated by Sauron Eye, which are physically located in France.
Under what condition could the surveillance system be used on the personal devices of employees?

  • A. Only if the employees give valid consent and the monitoring is narrowly limited to their professional tasks.
  • B. Only if the employer offers an adequate compensation for using the employee's devices.
  • C. Only if the cloud that stores the monitoring data is certified by the EDPB as GDPR compliant.
  • D. Only if the monitoring system is manufactured by a European vendor storing the monitoring data within the EU.

Answer: A

Explanation:
The General Data Protection Regulation (GDPR) does not prohibit surveillance of employees in the workplace. Still, it requires employers to follow special rules to ensure that the rights and freedoms of employees are protected when processing their personal data. The GDPR applies to any processing of personal data in the context of the activities of an establishment of a controller or a processor in the EU, regardless of whether the processing takes place in the EU or not. The GDPR also applies to the processing of personal data of data subjects who are in the EU by a controller or processor not established in the EU, where the processing activities are related to the offering of goods or services to data subjects in the EU or the monitoring of their behaviour as far as their behaviour takes place within the EU.
The GDPR requires that any processing of personal data must be lawful, fair and transparent, and based on one of the six legal grounds specified in the regulation. The most relevant legal grounds for employee surveillance are the legitimate interests of the employer, the performance of a contract with the employee, or the compliance with a legal obligation. The GDPR also requires that any processing of personal data must be limited to what is necessary for the purposes for which they are processed, and that the data subjects must be informed of the purposes and the legal basis of the processing, as well as their rights and the safeguards in place to protect their data.
The GDPR also imposes specific obligations and restrictions on the processing of special categories of personal data, such as biometric data, which reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or which are processed for the purpose of uniquely identifying a natural person. The processing of such data is prohibited, unless one of the ten exceptions listed in the regulation applies. The most relevant exceptions for employee surveillance are the explicit consent of the data subject, the necessity for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law, or the necessity for reasons of substantial public interest.
The GDPR also sets out the rules and requirements for the transfer of personal data to third countries or international organisations, which do not ensure an adequate level of data protection. The transfer of such data is only allowed if the controller or processor has provided appropriate safeguards, such as binding corporate rules, standard contractual clauses, codes of conduct or certification mechanisms, and if the data subjects have enforceable rights and effective legal remedies.
Based on the scenario, the only condition under which the surveillance system could be used on the personal devices of employees is if the employees give valid consent and the monitoring is narrowly limited to their professional tasks. This option is the most consistent with the GDPR's principles and requirements, as it:
Is based on a valid legal ground for the processing of personal data, namely the consent of the data subject, which must be freely given, specific, informed and unambiguous, and which can be withdrawn at any time.
Is limited to what is necessary for the purposes of the monitoring, as it only covers the work-related activities and communications of the employees, and excludes the private or personal ones.
Is transparent to the employees, as it informs them of the monitoring and its precise scope, and gives them the opportunity to object or opt out of the monitoring.
Does not involve the processing of special categories of personal data, such as biometric data or data revealing political opinions or trade union membership, which are not necessary or proportionate for the purposes of the monitoring, and which do not fall under any of the exceptions listed in the regulation.
Does not involve the transfer of personal data to a third country, such as China, which does not provide an adequate level of data protection, and which may pose additional risks for the rights and freedoms of the employees.
The other options listed in the question are not valid conditions for using the surveillance system on the personal devices of employees, as they:
Are not based on a valid legal ground for the processing of personal data, as they either rely on the legitimate interests of the employer, which are not balanced with the rights and freedoms of the employees, or on the compliance with a legal obligation, which does not apply to the use of personal devices.
Are not limited to what is necessary for the purposes of the monitoring, as they involve the collection and processing of excessive and irrelevant personal data, such as camera and microphone monitoring, screen captures, keystrokes, and facial recognition data, which go beyond the scope of the work performed by the employees, and intrude into their private or personal sphere.
Are not transparent to the employees, as they do not inform them of the monitoring and its precise scope, and do not give them the opportunity to object or opt out of the monitoring.
Involve the processing of special categories of personal data, such as biometric data or data revealing political opinions or trade union membership, which are not necessary or proportionate for the purposes of the monitoring, and which do not fall under any of the exceptions listed in the regulation.
Involve the transfer of personal data to a third country, such as China, which does not provide an adequate level of data protection, and which may pose additional risks for the rights and freedoms of the employees.
References:
GDPR, Articles 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 44, 45, 46, 47, 48, and
49.
EDPB Guidelines 3/2019 on processing of personal data through video devices, pages 5, 6, 7, 8, 9, 10, 11, 12,
13, and 14.
EDPB Guidelines 07/2020 on the concepts of controller and processor in the GDPR, pages 19, 20, 21, 22, 23,
24, 25, 26, 27, and 28.
EDPB Guidelines 4/2019 on Article 25 Data Protection by Design and by Default, pages 5, 6, 7, 8, 9, 10, 11,
12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, and 28.
EDPB Guidelines 2/2018 on derogations of Article 49 under Regulation 2016/679, pages 4, 5, 6, 7, 8, 9, 10,
11, and 12.
Data protection: GDPR and employee surveilance | Feature | Law Gazette, paragraphs 1, 2, 3, 4, 5, 6, 7, and 8.


NEW QUESTION # 147
SCENARIO
Please use the following to answer the next question:
Jack worked as a Pharmacovigiliance Operations Specialist in the Irish office of a multinational pharmaceutical company on a clinical trial related to COVID-19. As part of his onboarding process Jack received privacy training He was explicitly informed that while he would need to process confidential patient data in the course of his work, he may under no circumstances use this data for anything other than the performance of work-related (asks This was also specified in the privacy policy, which Jack signed upon conclusion of the training.
After several months of employment, Jack got into an argument with a patient over the phone. Out of anger he later posted the patient's name and hearth information, along with disparaging comments, on a social media website. When this was discovered by his Pharmacovigilance supervisors. Jack was immediately dismissed Jack's lawyer sent a letter to the company stating that dismissal was a disproportionate sanction, and that if Jack was not reinstated within 14 days his firm would have no alternative but to commence legal proceedings against the company. This letter was accompanied by a data access request from Jack requesting a copy of "all personal data, including internal emails that were sent/received by Jack or where Jack is directly or indirectly identifiable from the contents In relation to the emails Jack listed six members of the management team whose inboxes he required access.
The company conducted an initial search of its IT systems, which returned a large amount of information They then contacted Jack, requesting that he be more specific regarding what information he required, so that they could carry out a targeted search Jack responded by stating that he would not narrow the scope of the information requester.
Under Article 82 of the GDPR ("Right to compensation and liability-), which party is liable for the damage caused by the data breach?

  • A. The pharmaceutical company is liable.
  • B. Jack and the pharmaceutical company are jointly liable.
  • C. Jack is liable
  • D. Both parties are exempt, as the company is involved in human health research

Answer: B


NEW QUESTION # 148
SCENARIO
Please use the following to answer the next question:
Liem, an online retailer known for its environmentally friendly shoes, has recently expanded its presence in Europe. Anxious to achieve market dominance, Liem teamed up with another eco friendly company, EcoMick, which sells accessories like belts and bags. Together the companies drew up a series of marketing campaigns designed to highlight the environmental and economic benefits of their products. After months of planning, Liem and EcoMick entered into a data sharing agreement to use the same marketing database, MarketIQ, to send the campaigns to their respective contacts.
Liem and EcoMick also entered into a data processing agreement with MarketIQ, the terms of which included processing personal data only upon Liem and EcoMick's instructions, and making available to them all information necessary to demonstrate compliance with GDPR obligations.
Liem and EcoMick then procured the services of a company called JaphSoft, a marketing optimization firm that uses machine learning to help companies run successful campaigns. Clients provide JaphSoft with the personal data of individuals they would like to be targeted in each campaign. To ensure protection of its clients' data, JaphSoft implements the technical and organizational measures it deems appropriate. JaphSoft works to continually improve its machine learning models by analyzing the data it receives from its clients to determine the most successful components of a successful campaign. JaphSoft then uses such models in providing services to its client-base. Since the models improve only over a period of time as more information is collected, JaphSoft does not have a deletion process for the data it receives from clients. However, to ensure compliance with data privacy rules, JaphSoft pseudonymizes the personal data by removing identifying information from the contact information. JaphSoft's engineers, however, maintain all contact information in the same database as the identifying information.
Under its agreement with Liem and EcoMick, JaphSoft received access to MarketIQ, which included contact information as well as prior purchase history for such contacts, to create campaigns that would result in the most views of the two companies' websites. A prior Liem customer, Ms. Iman, received a marketing campaign from JaphSoft regarding Liem's as well as EcoMick's latest products. While Ms. Iman recalls checking a box to receive information in the future regarding Liem's products, she has never shopped EcoMick, nor provided her personal data to that company.
For what reason would JaphSoft be considered a controller under the GDPR?

  • A. It has been provided access to personal data in the MarketIQ database.
  • B. It makes decisions regarding the technical and organizational measures necessary to protect the personal data.
  • C. It uses personal data to improve its products and services for its client-base through machine learning.
  • D. It determines how long to retain the personal data collected.

Answer: C

Explanation:
According to the GDPR, a data controller is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data (Art
4(7) of GDPR). A data processor is the natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller (Art 4(8) of GDPR). In this case, JaphSoft would be considered a controller under the GDPR because it uses the personal data it receives from Liem and EcoMick to improve its own products and services through machine learning. This means that JaphSoft determines the purposes and means of this processing activity, which is not covered by the agreement with Liem and EcoMick. JaphSoft also decides how long to retain the personal data, which is another indication of its controller role. The other options are not sufficient to establish JaphSoft as a controller, as they could also apply to a processor. Having access to personal data in the MarketIQ database does not imply that JaphSoft determines the purposes and means of the processing. It could be acting on behalf of Liem and EcoMick, who are the controllers of the data in the database. Making decisions regarding the technical and organizational measures necessary to protect the personal data is also a duty of a processor, who must implement appropriate security measures in accordance with the GDPR and the instructions of the controller (Art 28 and Art 32 of GDPR). References:
* GDPR, Art 4, Art 28, Art 32
* Free CIPP/E Study Guide, p. 15
* European Data Protection Law & Practice, p. 123
* What is a data controller or a data processor?
* CNIL publishes guidance on data processing roles under EU GDPR
* Guide for multi-controller situations under the GDPR


NEW QUESTION # 149
Which of the following Convention 108+ principles, as amended in 2018, is NOT consistent with a principle found in the GDPR?

  • A. The necessity of the bulk collection of personal data by the government.
  • B. The obligation of companies to declare data breaches.
  • C. The requirement to demonstrate compliance to a supervisory authority.

Answer: C


NEW QUESTION # 150
Which mechanism, introduced by the GDPR as a means of ensuring both compliance and transparency, allows for the possibility of personal data transfers to third countries under Article 42?

  • A. Approved certifications.
  • B. Law enforcement requests.
  • C. Binding corporate rules.
  • D. Standard contractual clauses.

Answer: A

Explanation:
The General Data Protection Regulation (GDPR) introduces a mechanism for personal data transfers to third countries or international organisations that do not ensure an adequate level of data protection, based on approved certifications. According to Article 42 of the GDPR, the European Commission, the European Data Protection Board (EDPB) and the national data protection authorities (DPAs) shall encourage the establishment of data protection certification mechanisms and of data protection seals and marks, for the purpose of demonstrating compliance with the GDPR of processing operations by controllers and processors.
The specific needs of micro, small and medium-sized enterprises shall be taken into account.
The GDPR also provides that the certification mechanisms shall be voluntary and available via a transparent process. The certification shall be issued by the competent supervisory authority or by the certification bodies accredited by the supervisory authority or by the national accreditation body. The certification shall be valid for a maximum period of three years and may be renewed, under the same conditions, if the relevant requirements continue to be met. The certification shall be withdrawn, as the case may be, by the competent supervisory authority or by the certification bodies, where the requirements for the certification are not or are no longer met.
The GDPR further stipulates that the certification shall be issued to a controller or processor who has demonstrated, in accordance with the approved certification criteria, that the processing of personal data is in compliance with the GDPR. The certification shall specify the scope and purpose of the processing, the criteria applied and the duration of the validity of the certification. The certification shall not reduce the responsibility of the controller or the processor for compliance with the GDPR and shall not be interpreted as an endorsement of the quality or reliability of the products or services of the controller or the processor by the supervisory authority or the certification body.
The GDPR also states that the certification mechanisms shall contribute to the proper application of the GDPR, taking account of the specific features of the various processing sectors and the different risks for the rights and freedoms of data subjects. The certification mechanisms shall allow for the verification of compliance with the GDPR of processing operations by controllers and processors not established in the EU, regardless of the location of the processing. The certification mechanisms shall also provide for the possibility to demonstrate compliance with the GDPR for personal data transfers to third countries or international organisations under Article 46, which sets out the rules and requirements for the transfer of personal data to third countries or international organisations based on appropriate safeguards, such as binding corporate rules, standard contractual clauses, codes of conduct or certification mechanisms.
References:
GDPR, Articles 42, 43, 44, 45, 46, 47, 48 and 49.
EDPB Guidelines 1/2018 on certification and identifying certification criteria in accordance with Articles 42 and 43 of the Regulation 2016/679, pages 5, 6, 7, 8, 9, 10, 11, 12, 13, 14 and 15.
Free CIPP/E Study Guide, pages 9, 10, 11 and 12.


NEW QUESTION # 151
What was the main failing of Convention 108 that led to the creation of the Data Protection Directive (Directive 95/46/EC)?

  • A. It was implemented in a fragmented manner by a small number of states.
  • B. Its penalties for violations of data protection rights were widely viewed as r sufficient.
  • C. It did not include protections for sensitive personal data
  • D. IT did not account for the rapid growth of the Internet

Answer: B


NEW QUESTION # 152
In the event of a data breach, which type of information are data controllers NOT required to provide to either the supervisory authorities or the data subjects?

  • A. The predicted consequences of the breach.
  • B. The contact details of the appropriate data protection officer.
  • C. The measures being taken to address the breach.
  • D. The type of security safeguards used to protect the data.

Answer: B


NEW QUESTION # 153
What is the key difference between the European Council and the Council of the European Union?

  • A. The European Council is comprised of the heads of each EU member state.
  • B. The Council of the European Union has a degree of legislative power.
  • C. The Council of the European Union is helmed by a president.
  • D. The European Council focuses primarily on issues involving human rights.

Answer: A

Explanation:
The European Council and the Council of the European Union are two different EU institutions that have similar names but distinct roles and memberships. The European Council is the body of leaders (heads of state or government) of the 27 EU member states that defines the EU's general political direction and priorities1. The European Council does not adopt EU legislation, but rather sets the agenda and gives guidance to the other EU institutions1. The Council of the European Union, informally known as the Council, is composed of national ministers from each EU member state, grouped by policy area1. The Council is one of the two legislative bodies of the EU, along with the European Parliament, and negotiates and adopts EU laws, coordinates member states' policies, and develops the EU's common foreign and security policy1. The key difference between the two institutions is that the European Council is comprised of the heads of each EU member state, while the Council of the European Union is comprised of the ministersof each EU member state12. References: European Council | Council of the European Union, What is the difference between EU Council, Council of the European Union, and Council of Europe?
Reference: https://www.quora.com/What-is-the-difference-between-the-European-Council-the-Council-of- the- European-Union-and-the-Council-of-Europe


NEW QUESTION # 154
When assessing the level of risk created by a data breach, which of the following would NOT have to be taken into consideration?

  • A. The size of any data processor involved.
  • B. The special characteristics of the data controller.
  • C. The ease of identification of individuals.
  • D. The nature, sensitivity and volume of personal data.

Answer: A

Explanation:
When assessing the level of risk created by a data breach, the size of any data processor involved would not have to be taken into consideration. According to the GDPR, a data breach is "a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed" 1. The GDPR requires data controllers and processors to notify the relevant supervisory authority of a data breach within 72 hours, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons 2. The GDPR also requires data controllers to communicate the data breach to the affected data subjects without undue delay, if the breach is likely to result in a high risk to their rights and freedoms 3.
The GDPR does not specify the exact criteria for determining the level of risk, but it provides some guidance in Recital 85, which states that "the likelihood and severity of the risk to the rights and freedoms of the data subject should be determined by reference to the nature, scope, context and purposes of the processing" . The recital also mentions some factors that could increase the risk, such as the ease of identification of individuals, the special categories of personal data, the large scale of the processing, or the special characteristics of the data controller . Therefore, these factors should be taken into consideration when assessing the level of risk created by a data breach.
However, the size of any data processor involved is not relevant for the risk assessment, as it does not affect the impact of the breach on the data subjects. The data processor is only responsible for processing the personal data on behalf of the data controller, and has no direct relationship with the data subjects . The data processor's obligations in case of a data breach are to notify the data controller without undue delay, and to assist the data controller in complying with its obligations under the GDPR . The data processor's size may affect its ability to fulfill these obligations, but it does not change the level of risk created by the data breach itself. References: 1: Article 4(12) of the GDPR 2: Article 33 of the GDPR 3: Article 34 of the GDPR :
Recital 85 of the GDPR : Article 4(8) of the GDPR : Article 28 of the GDPR I hope this helps. If you have any other questions, please feel free to ask. #


NEW QUESTION # 155
The transparency principle is most directly related to which of the following rights?

  • A. Right to be informed.
  • B. Right to be forgotten.
  • C. Right to restriction of processing.
  • D. Right to object

Answer: A

Explanation:
The transparency principle, as stated in Article 5(1)(a) of the GDPR, requires that personal data be processed lawfully, fairly and in a transparent manner in relation to the data subject. This principle is closely linked to the right to be informed, as specified in Articles 13 and 14 of the GDPR, which oblige the controller to provide the data subject with certain information about the processing of their personal data, such as the identity and contact details of the controller, the purposes and legal basis of the processing, the recipients or categories of recipients of the personal data, the existence of the data subject's rights, and the retention period or criteria for the personal data. The right to be informed aims to ensure that the data subject is aware of and can verify the lawfulness of the processing, and to enable them to exercise their rights effectively. Therefore, the transparency principle is most directly related to the right to be informed. References:
* Article 5(1)(a) of the GDPR
* Article 13 of the GDPR
* Article 14 of the GDPR
* IAPP CIPP/E Study Guide, page 31


NEW QUESTION # 156
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 Asi a. 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?

  • A. The company has offices in the EU.
  • B. The company's data center is located in a country outside the EU.
  • C. The company employs staff in the EU.
  • D. The company's products are marketed directly to EU customers.

Answer: D

Explanation:
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 home and have the character's abilities remain intact.
Why is this company obligated to comply with the GDPR?
A . The company has offices in the EU. B. The company employs staff in the EU. C. The company's data center is located in a country outside the EU. D. The company's products are marketed directly to EU customers.
Verified Answe r: D . The company's products are marketed directly to EU customers.
According to section 6(1) of the GDPR1, personal data shall be processed by organisations, which offer goods or services or otherwise carry out activities, in relation to which processing of personal data may be regarded as relevant for their legitimate interests. The legitimate interests referred to are those arising from the performance of a task carried out in their name or on their behalf, or for their own purposes. The legitimate interests referred to are those arising from the performance of a task carried out in their name or on their behalf, or for their own purposes. The legitimate interests referred to are those arising from the performance of a task carried out in their name or on their behalf, or for their own purposes. The legitimate interests referred to are those arising from the performance of a task carried out in their name or on their behalf, or for their own purposes. The legitimate interests referred to are those arising from the performance of a task carried out in their name or on their behalf, or for their own purposes. The legitimate interests referred to are those arising from the performance of a task carried out in their name or on their behalf, or for their own purposes. The legitimate interests referred to are those arising from the performance


NEW QUESTION # 157
Which of the following describes a mandatory requirement for a group of undertakings that wants to appoint a single data protection officer?

  • A. The group of undertakings must obtain approval from a supervisory authority.
  • B. The data protection officer must be located in the country where the data controller has its main establishment.
  • C. The data protection officer must be easily accessible from each establishment where the undertakings are located.
  • D. The group of undertakings must be comprised of organizations of similar sizes and functions.

Answer: C

Explanation:
Reference https://www.privacy-regulation.eu/en/article-37-designation-of-the-data-protection-officer- GDPR.htm


NEW QUESTION # 158
SCENARIO
Please use the following to answer the next question:
Joe is the new privacy manager for Who-R-U, a Canadian business that provides DNA analysis. The company is headquartered in Montreal, and all of its employees are located there. The company offers its services to Canadians only: Its website is in English and French, it accepts only Canadian currency, and it blocks internet traffic from outside of Canada (although this solution doesn't prevent all non-Canadian traffic). It also declines to process orders that request the DNA report to be sent outside of Canada, and returns orders that show a non-Canadian return address.
Bob, the President of Who-R-U, thinks there is a lot of interest for the product in the EU, and the company is exploring a number of plans to expand its customer base.
The first plan, collegially called We-Track-U, will use an app to collect information about its current Canadian customer base. The expansion will allow its Canadian customers to use the app while traveling abroad. He suggests that the company use this app to gather location information. If the plan shows promise, Bob proposes to use push notifications and text messages to encourage existing customers to pre-register for an EU version of the service. Bob calls this work plan, We-Text-U. Once the company has gathered enough pre- registrations, it will develop EU-specific content and services.
Another plan is called Customer for Life. The idea is to offer additional services through the company's app, like storage and sharing of DNA information with other applications and medical providers. The company's contract says that it can keep customer DNA indefinitely, and use it to offer new services and market them to customers. It also says that customers agree not to withdraw direct marketing consent. Paul, the marketing director, suggests that the company should fully exploit these provisions, and that it can work around customers' attempts to withdraw consent because the contract invalidates them.
The final plan is to develop a brand presence in the EU. The company has already begun this process. It is in the process of purchasing the naming rights for a building in Germany, which would come with a few offices that Who-R-U executives can use while traveling internationally. The office doesn't include any technology or infrastructure; rather, it's simply a room with a desk and some chairs.
On a recent trip concerning the naming-rights deal, Bob's laptop is stolen. The laptop held unencrypted DNA reports on 5,000 Who-R-U customers, all of whom are residents of Canada. The reports include customer name, birthdate, ethnicity, racial background, names of relatives, gender, and occasionally health information.
Who-R-U is NOT required to notify the local German DPA about the laptop theft because?

  • A. There is no evidence that the thieves have accessed the data on the laptop.
  • B. The company isn't a controller established in the Union.
  • C. The laptop belonged to a company located in Canada.
  • D. The data isn't considered personally identifiable financial information.

Answer: B

Explanation:
According to the GDPR, a data breach must be notified to the supervisory authority of the member state where the controller or processor is established, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons1. The GDPR defines a controller as "the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data"2. The GDPR also specifies that a controller or processor is considered to be established in the Union if it has "an effective and real exercise of activity through stable arrangements" in the Union, regardless of its legal form or location of its headquarters3.
In this scenario, Who-R-U is not a controller established in the Union, because it does not have any stable arrangements in the Union that involve the processing of personal data. The company only offers its services to Canadians, and does not target or monitor individuals in the Union. The fact that it has purchased the naming rights for a building in Germany, which comes with a few offices, does not constitute an effective and real exercise of activity in the Union, as the offices do not include any technology or infrastructure for processing personal data, and are only used by executives while traveling internationally. Therefore, Who-R- U is not subject to the GDPR's data breach notification obligation, and is not required to notify the local German DPA about the laptop theft.
References:
* Art. 33 GDPR - Notification of a personal data breach to the supervisory authority
* Art. 4 GDPR - Definitions
* Art. 3 GDPR - Territorial scope
* Guidelines 9/2022 on personal data breach notification under GDPR
* Guidelines 3/2018 on the territorial scope of the GDPR
I hope this helps you understand the GDPR and data breach notification better. If you have any other questions, please feel free to ask me. #


NEW QUESTION # 159
What must a data controller do in order to make personal data pseudonymous?

  • A. Remove all indirect data identifiers and dispose of them securely.
  • B. Encrypt the data in order to prevent any unauthorized access or modification.
  • C. Use the data only in aggregated form for research purposes.
  • D. Separately hold any information that would allow linking the data to the data subject.

Answer: D

Explanation:
Pseudonymisation is a method that allows you to switch the original data set (for example, e-mail or a name) with an alias or pseudonym, or, in other words, a value which does not allow the individual to be directly identified1. It is a reversible process that de-identifies data but allows the re-identification later on if necessary1. This is a well-known data management technique highly recommended by the General Data Protection Regulation (GDPR) as one of the data protection methods2. To make personal data pseudonymous, a data controller must separately hold any information that would allow linking the data to the data subject, such as a key or a code, and ensure that this information is kept securely and subject to technical and organisational measures to prevent unauthorised access or re-identification23. The other options are not correct, as they either describe other data protection methods, such as encryption or anonymisation, or do not meet the definition of pseudonymisation under the GDPR. Reference: Pseudonymization according to the GDPR, Pseudonymisation - Wikipedia, Anonymisation and pseudonymisation | Data Protection Commissioner


NEW QUESTION # 160
Article 29 Working Party has emphasized that the GDPR forbids "forum shopping", which occurs when companies do what?

  • A. Choose the data protection officer that is most sympathetic to their business concerns.
  • B. Select third-party processors on the basis of cost rather than quality of privacy protection.
  • C. Designate their main establishment in member state with the most flexible practices.
  • D. File appeals of infringement judgments with more than one EU institution simultaneously.

Answer: C


NEW QUESTION # 161
Rental Market Champions (RMC) is a real estate agency, providing residential property rental services across Croatia. RMC processes personal data on their tenants, including names, contact details, employment data, financial information, credit scores and executed tenancy agreements.
RMC receives notification from a cybersecurity firm that RMC tenants' personal data have been posted to the dark web by a threat actor. Subsequent investigation by RMC confirms that their systems have been compromised and that sample files released on the dark web by the threat actor do relate to RMC customers.
RMC should notify the relevant supervisory authority of the data breach no later than 72 hours from which of the following actions?

  • A. After receiving notification from the cybersecurity firm.
  • B. After establishing that customers' personal data have been compromised.
  • C. After determining that the data breach is likely to result in a risk to the rights and freedoms of customers.
  • D. After collating the information needed to notify the relevant supervisory authority.

Answer: C

Explanation:
UnderArticle 33 GDPR, a controller must notify the supervisory authority "without undue delay and, where feasible, not later than 72 hours after having become aware of it," unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons.
TheEDPB Guidelines 9/2022 on personal data breach notificationclarify that "awareness" occurs when the controller has areasonable degree of certaintythat a security incident has led to personal data being compromised,andit has assessed that the breach is likely to result in risk.
Thus, the 72-hour clock startsnot when first informed (D)or when data compromise is suspected (C), but once the controller determines that the breach is likely to pose risksto affected individuals. Collating additional details (B) may continue after notification, but cannot delay the notification itself.
#Reference:
* GDPR, Article 33(1)
* EDPB Guidelines 9/2022, Section II.A "When to notify"
* CIPP/E Textbook (3rd ed.), Chapter 10 "Security of Personal Data" (breach notification obligations)


NEW QUESTION # 162
According to the European Data Protection Board, controllers responding to a data subject access request can refuse to provide a copy of personal data under certain conditions. Which of the following is NOT one of these conditions?

  • A. If there is such a large amount of data that the controller cannot identify the data subject of the request.
  • B. If the personal data was processed in the past but is no longer at the controller's disposal at the time of the request.
  • C. If the controller is unable to use end-to-end encrypted emails for responding to such requests.
  • D. If the data subject access request was sent to an employee that is not involved in the processing of such requests.

Answer: C

Explanation:
The right of access is one of the fundamental rights of data subjects under the GDPR. It allows data subjects to obtain from the controller confirmation as to whether or not personal data concerning them are being processed, and, where that is the case, access to the personal data and certain information about the processing. The controller must provide a copy of the personal data undergoing processing to the data subject, unless the data subject requests otherwise. The right of access is not absolute and may be subject to limitations, restrictions or exceptions, in accordance with the GDPR and the national laws of the member states.
The EDPB has issued draft guidelines on the right of access, which provide more detailed guidance on how to handle data subject access requests and what are the possible grounds for refusing to provide a copy of the personal data. According to the draft guidelines, the controller can refuse to provide a copy of the personal data in the following situations:
If the data subject access request was sent to an employee that is not involved in the processing of such requests. In this case, the controller must inform the data subject of the appropriate contact point for submitting the request and must not consider the request as received until it reaches the designated person or unit. This does not mean that the controller can ignore or delay the request, but rather that the controller must ensure that the request is forwarded to the responsible person or unit as soon as possible.
If there is such a large amount of data that the controller cannot identify the data subject of the request. In this case, the controller can ask the data subject to provide additional information to enable the identification of the data subject, such as a unique identifier, a reference number, a specific time period, a location or a context of the processing. The controller must not ask for more information than is necessary and must not use the information for any other purpose than verifying the identity of the data subject.
If the personal data was processed in the past but is no longer at the controller's disposal at the time of the request. In this case, the controller must inform the data subject that the personal data are no longer available and explain the reasons why the personal data have been erased, anonymised, archived or otherwise disposed of. The controller must also provide the data subject with any relevant information about the retention period, the archiving policy, the anonymisation process or the disposal method of the personal data.
The controller cannot refuse to provide a copy of the personal data in the following situation:
If the controller is unable to use end-to-end encrypted emails for responding to such requests. In this case, the controller must still provide a copy of the personal data to the data subject, but must ensure that the communication is secure and that the personal data are protected from unauthorised or unlawful access, disclosure, alteration or destruction. The controller can use alternative means of communication, such as secure online platforms, password-protected files, encrypted devices or postal mail, depending on the preferences and circumstances of the data subject. The controller must also inform the data subject of the risks involved in the chosen communication method and obtain the data subject's consent before sending the personal data.
References:
GDPR, Articles 12, 13, 14, 15, 23 and 34.
EDPB Guidelines 01/2022 on data subject rights - Right of access Version 2, pages 6, 7, 8, 9, 10, 11, 12, 13,
14, 15 and 16.


NEW QUESTION # 163
SCENARIO
Please use the following to answer the next question:
WonderkKids provides an online booking service for childcare. Wonderkids is based in France, but hosts its website through a company in Switzerland. As part of their service, WonderKids will pass all personal data provided to them to the childcare provider booked through their system. The type of personal data collected on the website includes the name of the person booking the childcare, address and contact details, as well as information about the children to be cared for including name, age, gender and health information. The privacy statement on Wonderkids' website states the following:
"WonderkKids provides the information you disclose to us through this website to your childcare provider for scheduling and health and safety reasons. We may also use your and your child's personal information for our own legitimate business purposes and we employ a third-party website hosting company located in Switzerland to store the data. Any data stored on equipment located in Switzerland meets the European Commission provisions for guaranteeing adequate safeguards for you and your child's personal information.
We will only share you and your child's personal information with businesses that we see as adding real value to you. By providing us with any personal data, you consent to its transfer to affiliated businesses and to send you promotional offers."
"We may retain you and your child's personal information for no more than 28 days, at which point the data will be depersonalized, unless your personal information is being used for a legitimate business purpose beyond 28 days where it may be retained for up to 2 years."
"We are processing you and your child's personal information with your consent. If you choose not to provide certain information to us, you may not be able to use our services. You have the right to: request access to you and your child's personal information; rectify or erase you or your child's personal information; the right to correction or erasure of you and/or your child's personal information; object to any processing of you and your child's personal information. You also have the right to complain to the supervisory authority about our data processing activities." What additional information must Wonderkids provide in their Privacy Statement?

  • A. Technical and organizational measures to protect data.
  • B. The categories of recipients with whom data will be shared.
  • C. Contact information of the hosting company.
  • D. How often promotional emails will be sent.

Answer: B

Explanation:
According to Article 13 of the GDPR, when personal data are collected from the data subject, the data controller must provide the data subject with the following information, among others1:
* The identity and the contact details of the controller and, where applicable, of the controller's representative;
* The contact details of the data protection officer, where applicable;
* The purposes of the processing for which the personal data are intended as well as the legal basis for the processing;
* The recipients or categories of recipients of the personal data, if any;
* Where applicable, the fact that the controller intends to transfer personal data to a third country or international organisation and the existence or absence of an adequacy decision by the Commission, or in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49(1), reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available.
In the scenario, Wonderkids provides some of this information in their Privacy Statement, but not all. They do not specify the categories of recipients with whom they will share the personal data of their customers and their children. They only state that they will share the data with businesses that they see as adding real value to the customers, which is vague and ambiguous. This does not comply with the GDPR requirement to inform the data subjects about the recipients or categories of recipients of their personal data, if any. Therefore, Wonderkids must provide this additional information in their Privacy Statement.
References:
* 1: Art. 13 GDPR Information to be provided where personal data are collected from the data subject


NEW QUESTION # 164
What is a reason the European Court of Justice declared the Data Retention Directive invalid in 2014?

  • A. The requirements specified that data must be held within the EU.
  • B. The requirements affected individuals without exception.
  • C. The requirements had limitations on how national authorities could use data.
  • D. The requirements were financially burdensome to EU businesses.

Answer: B

Explanation:
The Data Retention Directive was a EU law that required providers of electronic communications services to retain certain data, such as traffic and location data, for a period of between six months and two years, for the purpose of preventing, investigating, detecting and prosecuting serious crime1. However, in 2014, the Court of Justice of the European Union declared the Directive invalid, because it violated the fundamental rights to respect for private life and to the protection of personal data, as enshrined in the Charter of Fundamental Rights of the EU2. The Court found that the Directive entailed a wide-ranging and particularly serious interference with those rights, without being limited to what is strictly necessary3. One of the reasons for this finding was that the Directive applied to all individuals, all means of electronic communication and all traffic data without any differentiation, limitation or exception, thus affecting the entire population of the EU4. The Court also noted that the Directive did not provide sufficient safeguards to ensure effective protection of the data against the risk of abuse and unlawful access, and did not require the data to be retained within the EU5. References: 1 Directive 2006/24/EC of the European Parliament and of the Council of 15 March 2006 on the retention of data generated or processed in connection with the provision of publicly available electronic communications services or of public communications networks and amending Directive 2002/58
/EC2 Charter of Fundamental Rights of the European Union3 Press release No 54/14 - Judgment in Joined Cases C-293/12 and C-594/12 Digital Rights Ireland and Seitlinger and Others4 Judgment of the Court (Grand Chamber) of 8 April 2014. Digital Rights Ireland Ltd v Minister for Communications, Marine and Natural Resources and Others and Karntner Landesregierung and Others. Requests for a preliminary ruling from the High Court (Ireland) and the Verfassungsgerichtshof (Austria). Joined cases C-293/12 and C-594
/125 Ibid.


NEW QUESTION # 165
SCENARIO
Please use the following to answer the next question:
Joe is the new privacy manager for Who-R-U, a Canadian business that provides DNA analysis. The company is headquartered in Montreal, and all of its employees are located there. The company offers its services to Canadians only: Its website is in English and French, it accepts only Canadian currency, and it blocks internet traffic from outside of Canada (although this solution doesn't prevent all non-Canadian traffic). It also declines to process orders that request the DNA report to be sent outside of Canada, and returns orders that show a non-Canadian return address.
Bob, the President of Who-R-U, thinks there is a lot of interest for the product in the EU, and the company is exploring a number of plans to expand its customer base.
The first plan, collegially called We-Track-U, will use an app to collect information about its current Canadian customer base. The expansion will allow its Canadian customers to use the app while traveling abroad. He suggests that the company use this app to gather location information. If the plan shows promise, Bob proposes to use push notifications and text messages to encourage existing customers to pre-register for an EU version of the service. Bob calls this work plan, We-Text-U. Once the company has gathered enough pre- registrations, it will develop EU-specific content and services.
Another plan is called Customer for Life. The idea is to offer additional services through the company's app, like storage and sharing of DNA information with other applications and medical providers. The company's contract says that it can keep customer DNA indefinitely, and use it to offer new services and market them to customers. It also says that customers agree not to withdraw direct marketing consent. Paul, the marketing director, suggests that the company should fully exploit these provisions, and that it can work around customers' attempts to withdraw consent because the contract invalidates them.
The final plan is to develop a brand presence in the EU. The company has already begun this process. It is in the process of purchasing the naming rights for a building in Germany, which would come with a few offices that Who-R-U executives can use while traveling internationally. The office doesn't include any technology or infrastructure; rather, it's simply a room with a desk and some chairs.
On a recent trip concerning the naming-rights deal, Bob's laptop is stolen. The laptop held unencrypted DNA reports on 5,000 Who-R-U customers, all of whom are residents of Canad a. The reports include customer name, birthdate, ethnicity, racial background, names of relatives, gender, and occasionally health information.
If Who-R-U decides to track locations using its app, what must it do to comply with the GDPR?

  • A. Get consent from the app users.
  • B. Provide a transparent notice to users.
  • C. Obtain a court order because location data is a special category of personal data.
  • D. Anonymize the data and add latency so it avoids disclosing real time locations.

Answer: A


NEW QUESTION # 166
......


The CIPP-E exam is one of the most widely recognized privacy certifications in the world. It covers a wide range of topics related to privacy and data protection in the EU, including the General Data Protection Regulation (GDPR), data processing, data transfers, and data breaches. CIPP-E exam tests the candidate's knowledge and understanding of privacy laws and regulations in the EU, as well as their ability to apply this knowledge to real-world scenarios.

 

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