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IAPP CIPP-E Exam (page: 2)
IAPP Certified Information Privacy Professional/Europe (CIPP/E)
Updated on: 12-Feb-2026

Viewing Page 2 of 55
CIPP-E PDF 307 Questions

SCENARIO

Please use the following to answer the next question:

Anna and Frank both work at Granchester University. Anna is a lawyer responsible for data protection, while Frank is a lecturer in the engineering department. The University maintains a number of types of records:
Student records, including names, student numbers, home addresses, pre-university information, university attendance and performance records, details of special educational needs and financial information.
Staff records, including autobiographical materials (such as curricula, professional contact files,

student evaluations and other relevant teaching files). Alumni records, including birthplaces, years of birth, dates of matriculation and conferrals of degrees. These records are available to former students after registering through Granchester's Alumni portal. Department for Education records, showing how certain demographic groups (such as first-generation students) could be expected, on average, to progress. These records do not contain names or identification numbers.
Under their security policy, the University encrypts all of its personal data records in transit and at rest.

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

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

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

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

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

  1. Student records
  2. Staff and alumni records
  3. Frank's performance database
  4. Department for Education records

Answer(s): C

Explanation:

According to the GDPR, a record of processing activities (RoPA) is a document that provides an overview of how personal data is processed within an organisation. It must include information on the types of personal data processed, the purposes for which the data is processed, and the measures taken to ensure the security of the data. A RoPA must be kept up to date and made available to the supervisory authority upon request.
In this scenario, Anna does not have to include Frank's performance database in her RoPA, because it does not contain any personal data. Personal data is any information relating to an identified or identifiable natural person. Frank's performance database only contains aggregated or anonymised data that cannot identify any individual student. Therefore, it does not fall under the definition of personal data under the GDPR.
However, Anna still has to complete her RoPA for all other types of records that are processed by Granchester University, such as student records, staff and alumni records, and Department for Education records. These records may contain personal data that needs to be minimised and protected in accordance with the GDPR principles. Anna also has to conduct a risk analysis before processing these records, as required by Article 35(2) of the GDPR4. She also has to report any security incidents involving these records, as required by Article 33(3) of the GDPR4.


Reference:

[Art. 30 GDPR ­ Records of processing activities]
[How do we document our processing activities?]
Records of Processing (Article 30) Guidance
GDPR Records of Processing Activities | Resources
Records of Processing Activities: A Key GDPR Compliance Requirement



SCENARIO

Please use the following to answer the next question:

Anna and Frank both work at Granchester University. Anna is a lawyer responsible for data protection, while Frank is a lecturer in the engineering department. The University maintains a number of types of records:
Student records, including names, student numbers, home addresses, pre-university information, university attendance and performance records, details of special educational needs and financial information.
Staff records, including autobiographical materials (such as curricula, professional contact files, student evaluations and other relevant teaching files). Alumni records, including birthplaces, years of birth, dates of matriculation and conferrals of degrees. These records are available to former students after registering through Granchester's Alumni portal. Department for Education records, showing how certain demographic groups (such as first-generation students) could be expected, on average, to progress. These records do not contain names or identification numbers.
Under their security policy, the University encrypts all of its personal data records in transit and at rest.

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

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

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

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

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

  1. More information about Frank's data protection training.
  2. More information about the extent of the information loss.
  3. More information about the algorithm Frank used to mask student numbers.
  4. More information about what students have been told and how the research will be used.

Answer(s): D

Explanation:

Before Anna determines whether Frank's performance database is permissible, she needs to know more information about the following aspects of the data processing:
The purpose and legal basis of the data processing, which should be clearly defined and documented in a data protection impact assessment (DPIA) or a similar document. The nature and extent of the personal data involved, which should be limited to what is necessary for the purpose and not retained longer than necessary.
The measures taken to ensure the security and confidentiality of the personal data, such as encryption, pseudonymization, access control, etc.
The rights and interests of the data subjects, such as their right to access, rectify, erase or restrict their personal data, as well as their right to object or withdraw consent. The potential risks and consequences of the data processing for the rights and freedoms of the data subjects, such as identity theft, discrimination, reputational damage, etc. In this case, Anna needs to know more information about what students have been told and how the research will be used. This is because:
The purpose of using student records for research purposes is not clear from Frank's description. He does not specify whether he has obtained consent from the students or their parents/guardians, or whether he has informed them about his research objectives and methods. The nature and extent of using student records for research purposes is not clear from Frank's description. He does not specify which student records he is using (e.g., by name or by reference number), how many records he is using (e.g., by cohort or by class), or how long he will keep them (e.g., until graduation or indefinitely).
The measures taken to ensure the security and confidentiality of using student records for research purposes are not clear from Frank's description. He does not specify whether he has encrypted his program or his laptop before transferring it to his home device, whether he has backed up his program or his laptop before losing it on the train, or whether he has reported his lost laptop to his IT department.
Therefore, Anna needs more information about these aspects before she can determine whether Frank's performance database is permissible under the GDPR.


Reference:

1: Free CIPP/E Study Guide - International Association of Privacy Professionals 2: CIPP/E Certification - International Association of Privacy Professionals



SCENARIO

Please use the following to answer the next question:

Anna and Frank both work at Granchester University. Anna is a lawyer responsible for data protection, while Frank is a lecturer in the engineering department. The University maintains a number of types of records:
Student records, including names, student numbers, home addresses, pre-university information, university attendance and performance records, details of special educational needs and financial information.
Staff records, including autobiographical materials (such as curricula, professional contact files, student evaluations and other relevant teaching files). Alumni records, including birthplaces, years of birth, dates of matriculation and conferrals of degrees. These records are available to former students after registering through Granchester's Alumni portal. Department for Education records, showing how certain demographic groups (such as first-generation students) could be expected, on average, to progress. These records do not contain names or identification numbers.
Under their security policy, the University encrypts all of its personal data records in transit and at rest.

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

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

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

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

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

  1. The data subjects are no longer current students of Frank's
  2. The processing will not negatively affect the rights of the data subjects
  3. The algorithms that Frank uses for the processing are technologically sound
  4. The data subjects gave their unambiguous consent for the original processing

Answer(s): A

Explanation:

A risk analysis is a process of identifying, assessing and mitigating the potential threats and vulnerabilities that may affect the personal data processing activities of an organization. A risk analysis is not a one-time activity, but a continuous and dynamic process that requires regular monitoring and updating. A risk analysis is also not a substitute for compliance with the GDPR, but a tool to help ensure compliance by identifying and addressing the legal obligations and best practices. According to the GDPR, an organization must conduct a data protection impact assessment (DPIA) before starting any new or significantly increased processing activity that may pose a high risk to the rights and freedoms of the data subjects. A DPIA is a systematic and documented process that aims to identify, evaluate and mitigate the risks associated with such processing activities. A DPIA must be carried out by or on behalf of the controller (the person or entity that determines the purposes and means of processing) or by another person acting on their behalf. In this scenario, Frank is conducting a DPIA for his new processing activity of analyzing his students' performance data in relation to Department for Education expectations. This processing activity poses a high risk to the rights and freedoms of his students, as it involves collecting, storing, using and transferring their personal data without their explicit consent or knowledge. Therefore, Frank must conduct a DPIA before starting this processing activity. However, there are some exceptions to this requirement. One of them is when the processing activity involves personal data that are no longer relevant for the original purpose for which they were collected or otherwise processed. In this case, Frank can use existing personal data without conducting a DPIA, as long as he ensures that they are adequate, relevant and limited to what is necessary for his new purpose.
Therefore, in this situation, Anna will find that a risk analysis is NOT necessary in this situation as long as the data subjects are no longer current students of Frank's. This means that Frank can use his existing student records without conducting a DPIA, as long as he ensures that they are adequate, relevant and limited to what is necessary for his new purpose.


Reference:

Risks and data protection impact assessments (DPIAs) | ICO What Are GDPR Risk Assessments and Why Are They Important? GDPR Compliance Risk Assessment Best Practices | Accountable Why risk assessments are essential for GDPR compliance



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

  1. The European Parliament
  2. The European Commission
  3. The Article 29 Working Party
  4. The European Council

Answer(s): B

Explanation:

According to Article 45 of the GDPR, the European Commission has the power to determine, on the basis of an assessment, whether a non-EU country, a territory or a sector within that country, or an international organisation ensures an adequate level of data protection. This means that the data protection rules and standards in that country or organisation are equivalent to those in the EU. The effect of an adequacy decision is that personal data can flow freely from the EU to that country or organisation without any further safeguards or authorisations. The European Commission has adopted adequacy decisions for several countries and organisations, such as Japan, Canada, and the EU-US Data Privacy Framework.


Reference:

Data protection adequacy for non-EU countries, Adequate Level of Protection



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

  1. Both govern international transfers of personal data
  2. Both govern the manual processing of personal data
  3. Both only apply to European Union countries
  4. Both require notification of processing activities to a supervisory authority

Answer(s): D

Explanation:

The GDPR and the Convention 108 are two important data protection instruments that aim to protect the rights and freedoms of individuals with regard to their personal data. They both have some similarities and some differences, but one common feature is that they both require notification of processing activities to a supervisory authority.
A supervisory authority is an independent public body that monitors and enforces compliance with data protection laws. In the EU, there are 47 national data protection authorities (DPAs) that have the power to impose administrative fines, issue guidelines, conduct investigations, and cooperate with other authorities. In the Council of Europe, there are 54 parties to the Convention 108 that have established their own supervisory authorities or have agreed to be supervised by an external authority.
Notification of processing activities is a requirement for any controller or processor of personal data that falls under the scope of the GDPR or the Convention 108. A controller is a natural or legal person who determines the purposes and means of the processing of personal data. A processor is a natural or legal person who processes personal data on behalf of a controller. Notification means informing the supervisory authority about certain aspects of the processing, such as:

The identity and contact details of the controller and processor The categories and sources of personal data
The purposes and legal basis for processing
The recipients or categories of recipients of personal data The retention period or criteria for determining it
The existence of any automated decision-making or profiling The rights of data subjects and how they can exercise them Notification can be done in various ways, such as:
Submitting a written notification form
Publishing a notice on a website or other platform
Sending an email or other electronic message
Using an online system or portal
Notification should be done as soon as possible after becoming aware of any relevant information about the processing. It should also be updated whenever there are significant changes in relation to the processing.
Therefore, both the GDPR and the Convention 108 require notification of processing activities to a supervisory authority. This is one way to ensure transparency, accountability, and compliance with data protection laws.


Reference:

https://rm.coe.int/090000168093b851



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