[Mar 19, 2025] Valid CIPP-E Test Answers Full-length Practice Certification Exams
Accurate & Verified 2025 New CIPP-E Answers As Experienced in the Actual Test!
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NEW QUESTION # 27
Pursuant to Article 4(5) of the GDPR, data is considered "pseudonymized" if?
- A. It cannot be attributed to a person under any circumstances.
- B. It can only be attributed to a person by a third party.
- C. It can only be attributed to a person by the controller.
- D. It cannot be attributed to a data subject without the use of additional information.
Answer: D
NEW QUESTION # 28
Under the GDPR, which of the following is true in regard to adequacy decisions involving cross-border transfers?
- A. The European Commission can adopt an adequacy decision for individual companies.
- B. To be considered as adequate, third countries must implement the EU General Data Protection Regulation into their national legislation.
- C. The European Commission can adopt, repeal or amend an existing adequacy decision.
- D. EU member states are vested with the power to accept or reject a European Commission adequacy decision.
Answer: C
Explanation:
According to Article 45 of the GDPR, the European Commission has the power to determine whether a third country, a territory or one or more specified sectors within a third country, or an international organisation ensures an adequate level of protection of personal data. This means that personal data can flow from the EU and the EEA to that third country without any further safeguard being necessary. The adequacy decision is based on an assessment of the legal framework, the enforcement mechanisms, the access by public authorities, the international commitments and the cooperation with the EU of the third country or organisation. The European Commission also monitors the functioning of the adequacy decisions and can repeal, amend or suspend them if the level of protection is no longer ensured. The European Commission has so far recognised several countries and organisations as providing adequate protection, such as Japan, Canada, Switzerland, the UK and the EU-US Data Privacy Framework. Reference: GDPR Article 45, Data protection adequacy for non-EU countries, Adequacy decisions | European Data Protection Board
NEW QUESTION # 29
SCENARIO
Please use the following to answer the next question:
ABC Hotel Chain and XYZ Travel Agency are U.S.-based multinational companies. They use an internet-based common platform for collecting and sharing their customer data with each other, in order to integrate their marketing efforts. Additionally, they agree on the data to be stored, how reservations will be booked and confirmed, and who has access to the stored data.
Mike, an EU resident, has booked travel itineraries in the past through XYZ Travel Agency to stay at ABC Hotel Chain's locations. XYZ Travel Agency offers a rewards program that allows customers to sign up to accumulate points that can later be redeemed for free travel. Mike has signed the agreement to be a rewards program member.
Now Mike wants to know what personal information the company holds about him. He sends an email requesting access to his data, in order to exercise what he believes are his data subject rights.
What are ABC Hotel Chain and XYZ Travel Agency's roles in this relationship?
- A. ABC Hotel Chain and XYZ Travel Agency are joint controllers.
- B. XYZ Travel Agency is the controller and ABC Hotel Chain is the processor.
- C. ABC Hotel Chain and XYZ Travel Agency are independent controllers.
- D. ABC Hotel Chain is the controller and XYZ Travel Agency is the processor.
Answer: A
Explanation:
ABC Hotel Chain and XYZ Travel Agency are joint controllers in this relationship, because they jointly determine the purposes and means of the processing of personal data of their customers. According to Article 26 of the GDPR, joint controllers are two or more controllers who jointly participate in the decision-making process regarding the processing of personal data 1. In this scenario, ABC Hotel Chain and XYZ Travel Agency use a common platform for collecting and sharing customer data, and they agree on the data to be stored, how reservations will be booked and confirmed, and who has access to the stored data. Therefore, they have a common influence on the processing of personal data and share a common objective of integrating their marketing efforts. Moreover, they offer a rewards program that allows customers to sign up to accumulate points that can be redeemed for free travel, which implies a joint benefit from the processing of personal data.
The other options are not correct because they do not reflect the actual roles of ABC Hotel Chain and XYZ Travel Agency in this relationship. A controller is a natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data 2. A processor is a natural or legal person who processes personal data on behalf of the controller 3. In this scenario, neither ABC Hotel Chain nor XYZ Travel Agency act solely or on behalf of the other in processing the personal data of their customers. Rather, they act together in a collaborative manner and share the responsibility and accountability for the processing of personal data. Therefore, they are joint controllers, not independent controllers or controller and processor. Reference: 1: Article 26 of the GDPR 2: Article 4(7) of the GDPR 3: Article 4(8) of the GDPR
NEW QUESTION # 30
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. An explanation of the security measures used when personal data is transferred to a third party.
- B. A privacy notice explaining the consequences for opting out of the use of cookies on a website.
- C. A privacy notice containing brief information whilst offering access to further detail.
- D. An efficient means of providing written consent in member states where they are required to do so.
Answer: C
Explanation:
Explanation
NEW QUESTION # 31
In which of the following cases would an organization MOST LIKELY be required to follow both ePrivacy and data protection rules?
- A. When paying a search engine company to give prominence to certain products and services within specific search results.
- B. When calling a potential customer to notify her of an upcoming product sale.
- C. When emailing a customer to announce that his recent order should arrive earlier than expected.
- D. When creating an untargeted pop-up ad on a website.
Answer: D
NEW QUESTION # 32
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?
- A. The information about the data processing involved has not been specified
- B. The NFC portal can read any data stored in the action figures
- C. The RFID tag in the action figures has the potential for misuse because of the toy's evolving capabilities
- D. The cloud service provider is in a country that has not been deemed adequate
Answer: A
NEW QUESTION # 33
SCENARIO
Please use the following to answer the next question:
Dynaroux Fashion ('Dynaroux') is a successful international online clothing retailer that employs approximately 650 people at its headquarters based in Dublin, Ireland. Ronan is their recently appointed data protection officer, who oversees the company's compliance with the General Data Protection Regulation (GDPR) and other privacy legislation.
The company offers both male and female clothing lines across all age demographics, including children. In doing so, the company processes large amounts of information about such customers, including preferences and sensitive financial information such as credit card and bank account numbers.
In an aggressive bid to build revenue growth, Jonas, the CEO, tells Ronan that the company is launching a new mobile app and loyalty scheme that puts significant emphasis on profiling the company's customers by analyzing their purchases. Ronan tells the CEO that: (a) the potential risks of such activities means that Dynaroux needs to carry out a data protection impact assessment to assess this new venture and its privacy implications; and (b) where the results of this assessment indicate a high risk in the absence of appropriate protection measures, Dynaroux may have to undertake a prior consultation with the Irish Data Protection Commissioner before implementing the app and loyalty scheme.
Jonas tells Ronan that he is not happy about the prospect of having to directly engage with a supervisory authority and having to disclose details of Dynaroux's business plan and associated processing activities.
Which of the following facts about Dynaroux would trigger a data protection impact assessment under the GDPR?
- A. The company plans to undertake profiling of its customers through analysis of their purchasing patterns.
- B. The company will be undertaking processing activities involving sensitive data categories such as financial and children's data.
- C. The company employs approximately 650 people and will therefore be carrying out extensive processing activities.
- D. The company intends to shift their business model to rely more heavily on online shopping.
Answer: A
Explanation:
According to the Free CIPP/E Study Guide, page 14, "the GDPR requires controllers to carry out a data protection impact assessment (DPIA) prior to processing where a type of processing, in particular using new technologies, and taking into account the nature, scope, context and purposes of the processing, is likely to result in a high risk to the rights and freedoms of natural persons." The GDPR also provides a list of examples of processing operations that require a DPIA, such as "a systematic and extensive evaluation of personal aspects relating to natural persons which is based on automated processing, including profiling, and on which decisions are based that produce legal effects concerning the natural person or similarly significantly affect the natural person" (Article 35(3)(a)). Therefore, the fact that Dynaroux plans to undertake profiling of its customers through analysis of their purchasing patterns would trigger a DPIA under the GDPR, as it involves a systematic and extensive evaluation of personal aspects based on automated processing that may significantly affect the customers. The other options are not necessarily cases where a DPIA is required, although they may involve other obligations under the GDPR, such as obtaining a valid legal basis, providing adequate safeguards, or informing the data subjects. Reference:
Free CIPP/E Study Guide, page 14
GDPR, Article 35
NEW QUESTION # 34
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?
- A. 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.
- B. 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.
- C. 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.
- D. Bedrock does not have a duty to transfer Louis's data to Zantrum if doing so is legitimately not technically feasible.
Answer: A
Explanation:
Explanation
NEW QUESTION # 35
SCENARIO
Please use the following to answer the next question:
Dynaroux Fashion ('Dynaroux') is a successful international online clothing retailer that employs approximately 650 people at its headquarters based in Dublin, Ireland. Ronan is their recently appointed data protection officer, who oversees the company's compliance with the General Data Protection Regulation (GDPR) and other privacy legislation.
The company offers both male and female clothing lines across all age demographics, including children. In doing so, the company processes large amounts of information about such customers, including preferences and sensitive financial information such as credit card and bank account numbers.
In an aggressive bid to build revenue growth, Jonas, the CEO, tells Ronan that the company is launching a new mobile app and loyalty scheme that puts significant emphasis on profiling the company's customers by analyzing their purchases. Ronan tells the CEO that: (a) the potential risks of such activities means that Dynaroux needs to carry out a data protection impact assessment to assess this new venture and its privacy implications; and (b) where the results of this assessment indicate a high risk in the absence of appropriate protection measures, Dynaroux may have to undertake a prior consultation with the Irish Data Protection Commissioner before implementing the app and loyalty scheme.
Jonas tells Ronan that he is not happy about the prospect of having to directly engage with a supervisory authority and having to disclose details of Dynaroux's business plan and associated processing activities.
Which of the following facts about Dynaroux would trigger a data protection impact assessment under the GDPR?
- A. The company plans to undertake profiling of its customers through analysis of their purchasing patterns.
- B. The company will be undertaking processing activities involving sensitive data categories such as financial and children's data.
- C. The company employs approximately 650 people and will therefore be carrying out extensive processing activities.
- D. The company intends to shift their business model to rely more heavily on online shopping.
Answer: A
NEW QUESTION # 36
What obligation does a data controller or processor have after appointing a data protection officer?
- A. To provide resources necessary to carry out the defined tasks of the data protection officer and to maintain his or her expert knowledge.
- B. To submit for approval to the data protection officer a code of conduct to govern organizational practices and demonstrate compliance with data protection principles.
- C. To ensure that the data protection officer acts as the sole point of contact for individuals' questions about their personal data.
- D. To ensure that the data protection officer receives sufficient instructions regarding the exercise of his or her defined tasks.
Answer: B
NEW QUESTION # 37
When does the European Data Protection Board (EDPB) recommend reevaluating whether a transfer tool is effectively providing a level of personal data protection that is in compliance with the European Union (EU) level?
- A. On an ongoing basis.
- B. Every three (3) years.
- C. After a personal data breach.
- D. Every year.
Answer: A
Explanation:
Reference:
According to the EDPB Recommendations 01/2020 on measures that supplement transfer tools to ensure compliance with the EU level of protection of personal data, exporters of personal data to third countries must monitor, on an ongoing basis, developments in those third countries that could affect the level of protection of the personal data they transfer1. This means that exporters must reevaluate whether the transfer tool they rely on, such as standard contractual clauses, binding corporate rules, codes of conduct, or certification mechanisms, is effectively providing a level of personal data protection that is in compliance with the EU level. The EDPB recommends that exporters document this reevaluation and any changes that result from it1. The EDPB does not specify a fixed time interval for this reevaluation, but rather states that it should be done on an ongoing basis, taking into account the specific circumstances of each transfer and any relevant developments in the third country.
1: EDPB Recommendations 01/2020 on measures that supplement transfer tools to ensure compliance with the EU level of protection of personal data, Version 2.0, adopted on 18 June 2021, paragraphs 85-86.
NEW QUESTION # 38
Under what circumstances might the "soft opt-in" rule apply in relation to direct marketing?
- A. Where an individual's details have been obtained from a bought-in marketing list.
- B. When an individual has not consented to the marketing.
- C. Where an individual is given the ability to unsubscribe from marketing emails sent to him.
- D. When an individual's details are obtained from their inquiries about buying a product.
Answer: D
NEW QUESTION # 39
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. Jack is liable
- B. Jack and the pharmaceutical company are jointly liable.
- C. Both parties are exempt, as the company is involved in human health research
- D. The pharmaceutical company is liable.
Answer: B
NEW QUESTION # 40
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?
- A. Verify that the request is applicable to the data collected before the GDPR entered into force.
- B. Verify that the personal data has not already been sent to the customer.
- C. Verify that the purpose of the request from the customer is in line with the GDPR.
- D. Verify that the identity of the customer can be proven by other means.
Answer: A
Explanation:
Explanation/Reference: https://fpf.org/wp-content/uploads/2018/11/GDPR_CCPA_Comparison-Guide.pdf
NEW QUESTION # 41
In which scenario is a Controller most likely required to undertake a Data Protection Impact Assessment?
- A. When personal data is being collected and combined with other personal data to profile the creditworthiness of individuals.
- B. When the controller is required to have a Data Protection Officer.
- C. When personal data is being transferred outside of the EEA.
- D. When the controller is collecting email addresses from individuals via an online registration form for marketing purposes.
Answer: A
Explanation:
According to the GDPR, a data protection impact assessment (DPIA) is a process to help identify and minimize the data protection risks of a project. A DPIA is required when the processing is likely to result in a high risk to the rights and freedoms of natural persons, taking into account the nature, scope, context and purposes of the processing. The GDPR provides a list of examples of processing operations that require a DPIA, such as:
Systematic and extensive evaluation of personal aspects relating to natural persons which is based on automated processing, including profiling, and on which decisions are based that produce legal effects concerning the natural person or similarly significantly affect the natural person.
Processing on a large scale of special categories of data or of personal data relating to criminal convictions and offences.
Systematic monitoring of a publicly accessible area on a large scale.
Therefore, an example of a scenario where a controller is most likely required to undertake a DPIA is when personal data is being collected and combined with other personal data to profile the creditworthiness of individuals, as this involves a systematic and extensive evaluation of personal aspects based on automated processing and profiling, and may have significant effects on the individuals. The other scenarios are not necessarily indicative of a high risk to the rights and freedoms of natural persons, and do not fall under the examples of processing operations that require a DPIA provided by the GDPR. Reference: Free CIPP/E Study Guide, page 37; CIPP/E Certification, page 18; GDPR, Article 35, Recital 91.
Reference:
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NEW QUESTION # 42
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