CIPP-E exam dump, dumps VCE for Certified Information Privacy Professional/Europe (CIPP/E)
CIPP-E exam dump, dumps VCE for Certified Information Privacy Professional/Europe (CIPP/E)
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IAPP Certified Information Privacy Professional/Europe (CIPP/E) Sample Questions (Q35-Q40):
NEW QUESTION # 35
Company X has entrusted the processing of their payroll data to Provider Y.
Provider Y stores this encrypted data on its server. The IT department of Provider Y finds out that someone managed to hack into the system and take a copy of the data from its server. In this scenario, whom does Provider Y have the obligation to notify?
- A. Law enforcement
- B. Company X
- C. The public
- D. The supervisory authority
Answer: A
NEW QUESTION # 36
Which sentence best describes proper compliance for an international organization using Binding Corporate Rules (BCRs) as a controller or processor?
- A. All employees must follow the privacy regulations of the jurisdictions where the current scope of their work is established.
- B. Employees must sign an ad hoc contractual agreement each time personal data is exported.
- C. All employees are subject to the rules in their entirety, regardless of where the work is taking place.
- D. Employees who control personal data must complete a rigorous certification procedure, as they are exempt from legal enforcement.
Answer: A
NEW QUESTION # 37
When assessing the level of risk created by a data breach, which of the following would NOT have to be taken into consideration?
- A. The ease of identification of individuals.
- B. The special characteristics of the data controller.
- C. The size of any data processor involved.
- D. The nature, sensitivity and volume of personal data.
Answer: C
Explanation:
When assessing the level of risk created by a data breach, the size of any data processor involved would not have to be taken into consideration. According to the GDPR, a data breach is "a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed" 1. The GDPR requires data controllers and processors to notify the relevant supervisory authority of a data breach within 72 hours, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons 2. The GDPR also requires data controllers to communicate the data breach to the affected data subjects without undue delay, if the breach is likely to result in a high risk to their rights and freedoms 3.
The GDPR does not specify the exact criteria for determining the level of risk, but it provides some guidance in Recital 85, which states that "the likelihood and severity of the risk to the rights and freedoms of the data subject should be determined by reference to the nature, scope, context and purposes of the processing" . The recital also mentions some factors that could increase the risk, such as the ease of identification of individuals, the special categories of personal data, the large scale of the processing, or the special characteristics of the data controller . Therefore, these factors should be taken into consideration when assessing the level of risk created by a data breach.
However, the size of any data processor involved is not relevant for the risk assessment, as it does not affect the impact of the breach on the data subjects. The data processor is only responsible for processing the personal data on behalf of the data controller, and has no direct relationship with the data subjects . The data processor's obligations in case of a data breach are to notify the data controller without undue delay, and to assist the data controller in complying with its obligations under the GDPR . The data processor's size may affect its ability to fulfill these obligations, but it does not change the level of risk created by the data breach itself. Reference: 1: Article 4(12) of the GDPR 2: Article 33 of the GDPR 3: Article 34 of the GDPR : Recital 85 of the GDPR : Article 4(8) of the GDPR : Article 28 of the GDPR I hope this helps. If you have any other questions, please feel free to ask.
NEW QUESTION # 38
Pursuant to Article 4(5) of the GDPR, data is considered "pseudonymized" if?
- A. It cannot be attributed to a data subject without the use of additional information.
- B. It can only be attributed to a person by the controller.
- C. It cannot be attributed to a person under any circumstances.
- D. It can only be attributed to a person by a third party.
Answer: A
Explanation:
Reference:
According to Article 4(5) of the GDPR, pseudonymization is "the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person." Therefore, option A is the correct definition of pseudonymization. Option B is incorrect because pseudonymized data can still be attributed to a person with the use of additional information. Option C is incorrect because pseudonymization does not depend on who can attribute the data to a person, but on how the data is processed. Option D is incorrect for the same reason as option C. Reference:
GDPR Article 4(5)
CIPP/E Study Guide, page 9
NEW QUESTION # 39
SCENARIO
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.
What would be the most appropriate response to Jacks data subject access request?
- A. The company should provide all requested information except for the emails, as they are excluded from data access request requirements under the GDPR.
- B. The company should cite the need for an extension, and agree to provide the information requested in Jack's original DSAR within a period of 3 months.
- C. The company should decline to provide any information, as the amount of information requested is too excessive to provide in one month.
- D. The company should not provide any information, as the company is headquartered outside of the EU.
Answer: C
Explanation:
According to Article 15 of the GDPR, data subjects have the right to access and receive a copy of their personal data, and other supplementary information, from the data controller1. However, this right is not absolute and may be subject to limitations or restrictions. One of the grounds for refusing or limiting a data subject access request (DSAR) is when the request is manifestly unfounded or excessive, in particular because of its repetitive character1. In such cases, the controller may either charge a reasonable fee, taking into account the administrative costs of providing the information, or refuse to act on the request1. The controller must inform the data subject of the reasons for not taking action and of the possibility of lodging a complaint with a supervisory authority or seeking a judicial remedy1.
In this scenario, Jack's DSAR is likely to be considered excessive, as he requests a copy of all personal data, including internal emails, that were sent or received by him or where he is directly or indirectly identifiable from the contents. This is a very broad and vague request, which would require the company to search and review a large amount of information, and potentially disclose confidential or sensitive data about other employees or third parties. The company has already contacted Jack, asking him to be more specific about what information he requires, but he refused to narrow the scope of his request. Therefore, the company has a valid reason to decline to provide any information, as the amount of information requested is too excessive to provide in one month, which is the general time limit for responding to a DSAR under the GDPR1. Therefore, option B is the correct answer.
Option A is incorrect because the company's headquarters location is irrelevant for the purpose of the DSAR, as the GDPR applies to any processing of personal data in the context of the activities of an establishment of a controller or a processor in the EU, regardless of whether the processing takes place in the EU or not2. The company has an establishment in Ireland, where Jack worked, and therefore is subject to the GDPR.
Option C is incorrect because the company cannot agree to provide the information requested in Jack's original DSAR within a period of 3 months, as this would violate the data subject's right of access and the principle of accountability under the GDPR. The company can only extend the time limit to respond to a DSAR by a further two months if the request is complex or if the controller receives a number of requests from the same data subject1. However, the company must inform the data subject of any such extension within one month of receipt of the request, together with the reasons for the delay1. In this case, the company has not done so, and has instead asked Jack to be more specific about his request.
Option D is incorrect because the company cannot provide all requested information except for the emails, as this would not comply with the data subject's right of access and the principle of transparency under the GDPR. The company must provide the data subject with a copy of the personal data undergoing processing, unless this adversely affects the rights and freedoms of others1. The emails are part of the personal data undergoing processing, and the company cannot exclude them from the DSAR without a valid reason. The company must also provide the data subject with the following supplementary information, unless the data subject already has it1:
* the purposes of the processing;
* the categories of personal data concerned;
* the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
* where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
* the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
* the right to lodge a complaint with a supervisory authority;
* where the personal data are not collected from the data subject, any available information as to their source;
* the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
References:
* Right of access
* Territorial scope
NEW QUESTION # 40
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