CIPP-E Exam Questions and Answers | Exam-Dumps (Page: 11)

QUESTION: 51

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

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

Answer(s): D

Explanation:

According to Article 37(2) of the GDPR, a group of undertakings may appoint a single data protection officer (DPO) provided that the DPO is easily accessible from each establishment. This means that the DPO should be able to communicate effectively with the data subjects and the supervisory authorities in the relevant languages and jurisdictions, and to perform the tasks referred to in Article 39 of the GDPR34. The accessibility of the DPO does not necessarily depend on the physical location of the DPO, but rather on the availability of the DPO to the relevant stakeholders via various means of communication. Therefore, the DPO does not have to be located in the country where the data controller has its main establishment, nor does the group of undertakings have to obtain approval from a supervisory authority or be comprised of organizations of similar sizes and functions to appoint a single DPO.

Reference:

CIPP/E Certification - International Association of Privacy Professionals, Free CIPP/E Study Guide - International Association of Privacy Professionals, GDPR - EUR-Lex, What's different about a group data protection officer?, Data Protection Officers: What US Companies Need to Know - Cooley

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

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QUESTION: 52

What obligation does a data controller or processor have after appointing a data protection officer?

To ensure that the data protection officer receives sufficient instructions regarding the exercise of his or her defined tasks.
To provide resources necessary to carry out the defined tasks of the data protection officer and to maintain his or her expert knowledge.
To ensure that the data protection officer acts as the sole point of contact for individuals' Questions: about their personal data.
To submit for approval to the data protection officer a code of conduct to govern organizational practices and demonstrate compliance with data protection principles.

Answer(s): B

Explanation:

According to the UK GDPR, the controller and the processor must support the data protection officer in performing the tasks referred to in Article 39 by providing resources necessary to carry out those tasks and access to personal data and processing operations, and to maintain his or her expert knowledge. The controller and the processor must also ensure that the data protection officer does not receive any instructions regarding the exercise of those tasks and that he or she reports directly to the highest management level of the controller or the processor.

Reference:

https://www.i-scoop.eu/gdpr/data-controller-data-controller-duties/

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QUESTION: 53

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?

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

Answer(s): 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).

Reference:

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

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QUESTION: 54

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.

Why would the consent provided by Ms. Iman NOT be considered valid in regard to JaphSoft?

She was not told which controller would be processing her personal data.
She only viewed the visual representations of the privacy notice Liem provided.
She did not read the privacy notice stating that her personal data would be shared.
She has never made any purchases from JaphSoft and has no relationship with the company.

Answer(s): C

Explanation:

The reason why the consent provided by Ms. Iman would not be considered valid in regard to JaphSoft is not because she did not provide her consent for her personal data to be shared with EcoMick, but because she was not told which controller would be processing her personal data. JaphSoft is a controller, as it determines the purpose and means of the processing of personal data, which is to improve its marketing optimization models and to provide better services to its customers. JaphSoft does not act only on the instructions of Liem and EcoMick, who are the original controllers of the personal data, but rather uses the data for its own benefit and interest. Therefore, JaphSoft should have obtained a separate consent from Ms. Iman, or relied on another lawful basis, such as legitimate interest, to process her personal data. Ms. Iman only gave consent to Liem, not to JaphSoft, and she was not informed that her personal data would be shared with or processed by another controller.

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QUESTION: 55

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.

JaphSoft's use of pseudonymization is NOT in compliance with the CDPR because?

JaphSoft failed to first anonymize the personal data.
JaphSoft pseudonymized all the data instead of deleting what it no longer needed.
JaphSoft was in possession of information that could be used to identify data subjects.
JaphSoft failed to keep personally identifiable information in a separate database.

Answer(s): B

Explanation:

According to the GDPR, pseudonymization is a technique that reduces the linkability of personal data to a specific data subject by replacing identifying attributes with pseudonyms. Pseudonymization is not a sufficient measure to anonymize personal data, which means that the data cannot be attributed to an identifiable person without additional information. Pseudonymization can help data controllers and processors to comply with the GDPR principles of data minimization, purpose limitation, and storage limitation, as well as to enhance the security and confidentiality of personal data.
In this scenario, JaphSoft's use of pseudonymization is not in compliance with the GDPR because of option C: JaphSoft was in possession of information that could be used to identify data subjects. This is because JaphSoft did not keep the additional information (the contact information) separately from the pseudonymized data (the identifying information), and did not apply technical and organizational measures to prevent the re-identification of the data subjects. This means that JaphSoft could potentially link the personal data to the individuals, and therefore, the data was not effectively pseudonymized. Moreover, JaphSoft did not have a deletion process for the data it received from clients, which could violate the principle of storage limitation that requires personal data to be kept no longer than necessary for the purposes for which they are processed.

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IAPP CIPP-E Exam (page: 11) IAPP Certified Information Privacy Professional/Europe (CIPP/E) Updated on: 15-Feb-2026

QUESTION: 51

Explanation:

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QUESTION: 52

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QUESTION: 53

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QUESTION: 54

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QUESTION: 55

Explanation:

IAPP CIPP-E Exam (page: 11)
IAPP Certified Information Privacy Professional/Europe (CIPP/E)
Updated on: 15-Feb-2026