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You will need to pass the Certified Information Privacy Professional/Europe (CIPP/E) (CIPP-E) exam to achieve the Certified Information Privacy Professional/Europe (CIPP/E) (CIPP-E) certification. Due to extremely high competition, passing the IAPP CIPP-E exam is not easy; however, possible. You can use BraindumpsPass products to pass the CIPP-E Exam on the first attempt. The Certified Information Privacy Professional/Europe (CIPP/E) (CIPP-E) practice exam gives you confidence and helps you understand the criteria of the testing authority and pass the IAPP CIPP-E exam on the first attempt.
| Section | Objectives |
|---|---|
| Topic 1: European Data Protection Law and Regulation | - GDPR Principles
|
| Topic 2: Introduction to European Data Protection | - Origins and Historical Context of Data Protection Law
|
| Topic 3: European Data Processing | - Controller and Processor Obligations
|
| Topic 4: European Data Protection Scope and Accountability | - Territorial and Material Scope
|
| Topic 5: Compliance with European Data Protection Law and Regulation | - Incident and Breach Management
|
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NEW QUESTION # 186
According to the Personal Data Protection Commission's (PDPC) "Guide to basic data anonymization techniques," recently adopted by the Spanish Data Protection Agency, which of the following is NOT a valid basic anonymization technique?
Answer: D
Explanation:
Data adjustment is not a valid basic anonymization technique according to the PDPC's guide12. Data adjustment refers to the modification of the original data values by adding or subtracting a random amount, or multiplying or dividing by a random factor3. This technique may preserve some statistical properties of the data, but it also introduces errors and inaccuracies that may affect the utility and quality of the data3. Moreover, data adjustment may not sufficiently protect the identity of individuals, as the adjusted data may still be linked or matched with other data sources3. Therefore, data adjustment is not recommended by the PDPC as a basic anonymization technique.
Reference:
1: GUIDE TO BASIC DATA ANONYMISATION TECHNIQUES Published 25 January 2018 - PDPC 2: GUIDE TO BASIC ANONYMISATION - PDPC 3: Guide to basic anonymisation and free tool from PDPC
NEW QUESTION # 187
SCENARIO
Please use the following to answer the next question:
Louis, a long-time customer of Bedrock Insurance, was involved in a minor car accident a few months ago.
Although no one was hurt, Louis has been plagued by texts and calls from a company called Accidentable offering to help him recover compensation for personal injury. Louis has heard about insurance companies selling customers' data to third parties, and he's convinced that Accidentable must have gotten his information from Bedrock Insurance.
Louis has also been receiving an increased amount of marketing information from Bedrock, trying to sell him their full range of their insurance policies.
Perturbed by this, Louis has started looking at price comparison sites on the internet and has been shocked to find that other insurers offer much cheaper rates than Bedrock, even though he has been a loyal customer for many years. When his Bedrock policy comes up for renewal, he decides to switch to Zantrum Insurance.
In order to activate his new insurance policy, Louis needs to supply Zantrum with information about his No Claims bonus, his vehicle and his driving history. After researching his rights under the GDPR, he writes to ask Bedrock to transfer his information directly to Zantrum. He also takes this opportunity to ask Bedrock to stop using his personal data for marketing purposes.
Bedrock supplies Louis with a PDF and XML (Extensible Markup Language) versions of his No Claims Certificate, but tells Louis it cannot transfer his data directly to Zantrum as this is not technically feasible.
Bedrock also explains that Louis's contract included a provision whereby Louis agreed that his data could be used for marketing purposes; according to Bedrock, it is too late for Louis to change his mind about this. It angers Louis when he recalls the wording of the contract, which was filled with legal jargon and very confusing.
In the meantime, Louis is still receiving unwanted calls from Accidentable Insurance. He writes to Accidentable to ask for the name of the organization that supplied his details to them. He warns Accidentable that he plans to complain to the data protection authority, because he thinks their company has been using his data unlawfully. His letter states that he does not want his data being used by them in any way.
Accidentable's response letter confirms Louis's suspicions. Accidentable is Bedrock Insurance's wholly owned subsidiary, and they received information about Louis's accident from Bedrock shortly after Louis submitted his accident claim. Accidentable assures Louis that there has been no breach of the GDPR, as Louis' s contract included, a provision in which he agreed to share his information with Bedrock's affiliates for business purposes.
Louis is disgusted by the way in which he has been treated by Bedrock, and writes to them insisting that all his information be erased from their computer system.
After Louis has exercised his right to restrict the use of his data, under what conditions would Accidentable have grounds for refusing to comply?
Answer: C
NEW QUESTION # 188
SCENARIO
Please use the following to answer the next question:
The fitness company Vigotron has recently developed a new app called M-Health, which it wants to market on its website as a free download. Vigotron's marketing manager asks his assistant Emily to create a webpage that describes the app and specifies the terms of use. Emily, who is new at Vigotron, is excited about this task. At her previous job she took a data protection class, and though the details are a little hazy, she recognizes that Vigotron is going to need to obtain user consent for use of the app in some cases. Emily sketches out the following draft, trying to cover as much as possible before sending it to Vigotron's legal department.
Registration Form
Vigotron's new M-Health app makes it easy for you to monitor a variety of health-related activities, including diet, exercise, and sleep patterns. M-Health relies on your smartphone settings (along with other third-party apps you may already have) to collect data about all of these important lifestyle elements, and provide the information necessary for you to enrich your quality of life. (Please click here to read a full description of the services that M-Health provides.) Vigotron values your privacy. The M-Heaith app allows you to decide which information is stored in it, and which apps can access your dat a. When your device is locked with a passcode, all of your health and fitness data is encrypted with your passcode. You can back up data stored in the Health app to Vigotron's cloud provider, Stratculous. (Read more about Stratculous here.) Vigotron will never trade, rent or sell personal information gathered from the M-Health app. Furthermore, we will not provide a customer's name, email address or any other information gathered from the app to any third- party without a customer's consent, unless ordered by a court, directed by a subpoena, or to enforce the manufacturer's legal rights or protect its business or property.
We are happy to offer the M-Health app free of charge. If you want to download and use it, we ask that you first complete this registration form. (Please note that use of the M-Health app is restricted to adults aged 16 or older, unless parental consent has been given to minors intending to use it.) First name:
Surname:
Year of birth:
Email:
Physical Address (optional*):
Health status:
*If you are interested in receiving newsletters about our products and services that we think may be of interest to you, please include your physical address. If you decide later that you do not wish to receive these newsletters, you can unsubscribe by sending an email to unsubscribe@vigotron.com or send a letter with your request to the address listed at the bottom of this page.
Terms and Conditions
1. Jurisdiction. [...]
2. Applicable law. [...]
3. Limitation of liability. [...]
Consent
By completing this registration form, you attest that you are at least 16 years of age, and that you consent to the processing of your personal data by Vigotron for the purpose of using the M-Health app. Although you are entitled to opt out of any advertising or marketing, you agree that Vigotron may contact you or provide you with any required notices, agreements, or other information concerning the services by email or other electronic means. You also agree that the Company may send automated emails with alerts regarding any problems with the M-Health app that may affect your well being.
Emily sends the draft to Sam for review. Which of the following is Sam most likely to point out as the biggest problem with Emily's consent provision?
Answer: A
NEW QUESTION # 189
SCENARIO
Please use the following to answer the next question:
Zandelay Fashion ('Zandelay') is a successful international online clothing retailer that employs approximately 650 people at its headquarters based in Dublin, Ireland. Martin 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, Jerry, the CEO, tells Martin 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. Martin tells the CEO that: (a) the potential risks of such activities means that Zandelay 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. Zandelay may have to undertake a prior consultation with the Irish Data Protection Commissioner before implementing the app and loyalty scheme.
Jerry tells Martin that he is not happy about the prospect of having to directly engage with a supervisory authority and having to disclose details of Zandelay's business plan and associated processing activities.
What must Zandelay provide to the supervisory authority during the prior consultation?
Answer: C
Explanation:
According to Article 36 of the GDPR, when a controller intends to process personal data that would result in a high risk to the rights and freedoms of data subjects, and a data protection impact assessment under Article 35 indicates that the risk cannot be mitigated by the controller, the controller must consult the supervisory authority before processing. The purpose of this prior consultation is to seek the advice of the supervisory authority on whether the processing complies with the GDPR and what measures can be taken to ensure compliance. During the prior consultation, the controller must provide the supervisory authority with the following information:
the respective responsibilities of the controller, joint controllers and processors involved in the processing, in particular for processing within a group of undertakings; the purposes and means of the intended processing; the measures and safeguards provided to protect the rights and freedoms of data subjects pursuant to the GDPR; the contact details of the data protection officer, if any; the data protection impact assessment provided for in Article 35; and any other information requested by the supervisory authority.
Therefore, the correct answer is B. An explanation of the purposes and means of the intended processing. This information is essential for the supervisory authority to understand the nature and scope of the processing and to assess its compliance with the GDPR. The other options are not required by Article 36, although they may be relevant for other aspects of the GDPR, such as the data protection by design and by default principle (A), the lawfulness of processing , or the designation of the data protection officer (D). Reference:
Article 36 of the GDPR, which regulates the prior consultation with the supervisory authority.
ICO guidance, which explains the process and requirements of the prior consultation.
EDPB guidelines, which provide further guidance on the criteria and procedure of the prior consultation.
NEW QUESTION # 190
SCENARIO
Please use the following to answer the next question:
Due to rapidly expanding workforce, Company A has decided to outsource its payroll function to Company B.
Company B is an established payroll service provider with a sizable client base and a solid reputation in the industry.
Company B's payroll solution for Company A relies on the collection of time and attendance data obtained via a biometric entry system installed in each of Company A's factories. Company B won't hold any biometric data itself, but the related data will be uploaded to Company B's UK servers and used to provide the payroll service. Company B's live systems will contain the following information for each of Company A's employees:
* Name
* Address
* Date of Birth
* Payroll number
* National Insurance number
* Sick pay entitlement
* Maternity/paternity pay entitlement
* Holiday entitlement
* Pension and benefits contributions
* Trade union contributions
Jenny is the compliance officer at Company A.
She first considers whether Company A needs to carry out a data protection impact assessment in relation to the new time and attendance system, but isn't sure whether or not this is required.
Jenny does know, however, that under the GDPR there must be a formal written agreement requiring Company B to use the time and attendance data only for the purpose of providing the payroll service, and to apply appropriate technical and organizational security measures for safeguarding the data. Jenny suggests that Company B obtain advice from its data protection officer. The company doesn't have a DPO but agrees, in the interest of finalizing the contract, to sign up for the provisions in full. Company A enters into the contract.
Weeks later, while still under contract with Company A, Company B embarks upon a separate project meant to enhance the functionality of its payroll service, and engages Company C to help. Company C agrees to extract all personal data from Company B's live systems in order to create a new database for Company B.
This database will be stored in a test environment hosted on Company C's U.S. server. The two companies agree not to include any data processing provisions in their services agreement, as data is only being used for IT testing purposes.
Unfortunately, Company C's U.S. server is only protected by an outdated IT security system, and suffers a cyber security incident soon after Company C begins work on the project. As a result, data relating to Company A's employees is visible to anyone visiting Company C's website. Company A is unaware of this until Jenny receives a letter from the supervisory authority in connection with the investigation that ensues. As soon as Jenny is made aware of the breach, she notifies all affected employees.
Under the GDPR, which of Company B's actions would NOT be likely to trigger a potential enforcement action?
Answer: A
NEW QUESTION # 191
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