CIPP-E Exam Questions and Answers | Exam-Dumps (Page: 3)

QUESTION: 11

Which aspect of the GDPR will likely have the most impact on the consistent implementation of data protection laws throughout the European Union?

That it essentially functions as a one-stop shop mechanism
That it takes the form of a Regulation as opposed to a Directive
That it makes notification of large-scale data breaches mandatory
That it makes appointment of a data protection officer mandatory

Answer(s): B

Explanation:

One of the main differences between a Regulation and a Directive in the EU law is that a Regulation is directly applicable and binding in all EU member states, without the need for national implementing measures, while a Directive sets out the objectives and principles that the member states must achieve, but leaves them the choice of form and methods to transpose it into their national laws. Therefore, by taking the form of a Regulation, the GDPR aims to harmonize and unify the data protection rules across the EU, and to ensure a consistent implementation and enforcement of the data protection laws throughout the EU. The other aspects of the GDPR listed in the question, such as the one-stop shop mechanism, the mandatory notification of large-scale data breaches, and the mandatory appointment of a data protection officer, are also important features of the GDPR, but they do not have the same impact on the consistency of the data protection laws as the form of a Regulation.

Reference:

Difference between A Regulation And Directive (European Law)1; EUR-Lex - 310401_2 -

EN - EUR-Lex2; EU GDPR vs. European Data Protection Directive 95/46/EC - Advisera3; Difference between GDPR and Data Protection Directive - Profolus

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QUESTION: 12

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

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

Answer(s): 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 platforms. 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 metadata. Such data can be used by competent national authorities for the prevention, investigation, detection or prosecution of criminal offences and safeguarding national security. 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 directive. 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 privacy.
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.

Reference:

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?

https://www.law.kuleuven.be/citip/en/archive/copy_of_publications/440retention-of- traffic-data- dumortier-goemans2f90.pdf (9)

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QUESTION: 13

What type of data lies beyond the scope of the General Data Protection Regulation?

Pseudonymized
Anonymized
Encrypted
Masked

Answer(s): B

Explanation:

: The General Data Protection Regulation (GDPR) is a data protection law that applies to the processing of personal data of individuals in the European Union (EU) and the European Economic Area (EEA). Personal data is any information relating to an identified or identifiable natural person, such as name, address, email, phone number, etc. The GDPR does not apply to personal data that is anonymized, meaning that it cannot be linked back to a specific individual. Anonymization can be achieved by removing or masking any identifying information from the data, such as using pseudonyms, aggregating or generalizing the data, or applying statistical methods.

Therefore, the type of data that lies beyond the scope of the GDPR is anonymized data.

Reference:

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

https://www.datainspektionen.se/other-lang/in-english/the-general-data-protection- regulation-gdpr/ the-purposes-and-scope-of-the-general-data-protection-regulation/ https://commission.europa.eu/law/law-topic/data-protection/reform/what-personal- data_en#:~:text=Different%20pieces%20of%20information%2C%20which,the%20scope%20of%20th e%20GDPR. B. ANONYMIZED Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data. Personal data that has been de- identified, encrypted or pseudonymised but can be used to re-identify a person remains personal data and falls within the scope of the GDPR. Personal data that has been rendered anonymous in such a way that the individual is not or no longer identifiable is no longer considered personal data. For data to be truly anonymised, the anonymisation must be irreversible.

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QUESTION: 14

Under what circumstances would the GDPR apply to personal data that exists in physical form, such as information contained in notebooks or hard copy files?

Only where the personal data is produced as a physical output of specific automated processing activities, such as printing, labelling, or stamping.
Only where the personal data is to be subjected to specific computerized processing, such as image scanning or optical character recognition.
Only where the personal data is treated by automated means in some way, such as computerized distribution or filing.
Only where the personal data is handled in a sufficiently structured manner so as to form part of a filing system.

Answer(s): D

Explanation:

The GDPR applies to all personal data, regardless of whether it exists in physical form or not. The GDPR defines personal data as any information relating to an identified or identifiable natural person, such as names, identification numbers, location data, or online identifiers. Therefore, any information that can be linked directly or indirectly to a natural person is considered personal data under the GDPR.
However, the GDPR also distinguishes between different types of processing activities and their legal bases. Processing activities are the operations performed on personal data, such as collection, storage, use, disclosure, or deletion. Processing activities can be either automated or manual. Automated processing means using technology to perform processing activities without human intervention. Manual processing means using human intervention to perform processing activities. The GDPR requires that any processing activity that involves personal data must comply with certain principles and conditions, such as lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality. These principles and conditions apply to both automated and manual processing activities. Therefore, the GDPR applies to personal data that exists in physical form only when it is processed by an automated means in some way that affects its rights and freedoms. For example, if a company scans paper documents and stores them electronically in a database without deleting them after a certain period of time or when they are no longer needed for the original purpose for which they were collected (Article 6), then this would be considered an automated processing activity that involves personal data in physical form.
However, the GDPR does not apply to personal data that exists in physical form when it is handled in a sufficiently structured manner so as to form part of a filing system. For example, if a company keeps paper documents in folders labeled with names and dates on their office shelves without scanning them or storing them electronically anywhere else (Article 5), then this would not be considered an automated processing activity that involves personal data in physical form.

Reference:

Physical Data - GDPR Summary
What GDPR Means for Your Physical Records - Access
Personal Data - Data Protection Act 2018

https://www.zimmerslaw.com/english-1/data-protection/

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QUESTION: 15

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.

Why is this company obligated to comply with the GDPR?

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

Answer(s): 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.
Answer
Verified

Answer(s): D. The company's products are marketed directly to EU customers.

Comprehensive 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

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IAPP CIPP-E Exam (page: 3) IAPP Certified Information Privacy Professional/Europe (CIPP/E) Updated on: 12-Feb-2026

QUESTION: 11

Explanation:

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QUESTION: 12

Explanation:

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QUESTION: 13

Explanation:

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QUESTION: 14

Explanation:

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QUESTION: 15

Explanation:

IAPP CIPP-E Exam (page: 3)
IAPP Certified Information Privacy Professional/Europe (CIPP/E)
Updated on: 12-Feb-2026