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IAPP Certified Information Privacy Professional/Europe (CIPP/E) Sample Questions (Q200-Q205):
NEW QUESTION # 200
A company plans to transfer employee health information between two of its entities in France. To maintain the security of the processing, what would be the most important security measure to apply to the health data transmission?
- A. Inform the data subject of the security measures in place.
- B. Encrypt the transferred data in transit and at rest.
- C. Conduct a data protection impact assessment.
- D. Ensure that the receiving entity has signed a data processing agreement.
Answer: A
NEW QUESTION # 201
A well-known video production company, based in Spain but specializing in documentaries filmed worldwide, has just finished recording several hours of footage featuring senior citizens in the streets of Madrid. Under what condition would the company NOT be required to obtain the consent of everyone whose image they use for their documentary?
- A. If the company limits the footage to data subjects solely of legal age.
- B. If obtaining consent is deemed to involve disproportionate effort.
- C. If the company's status as a documentary provider allows it to claim legitimate interest.
- D. If obtaining consent is deemed voluntary by local legislation.
Answer: D
NEW QUESTION # 202
Read the following steps:
Discover which employees are accessing cloud services and from which devices and apps Lock down the data in those apps and devices Monitor and analyze the apps and devices for compliance Manage application life cycles Monitor data sharing An organization should perform these steps to do which of the following?
- A. Ensure cloud vendors are complying with internal data use policies.
- B. Institute a GDPR-compliant employee monitoring process.
- C. Pursue a GDPR-compliant Privacy by Design process.
- D. Maintain a secure Bring Your Own Device (BYOD) program.
Answer: D
Explanation:
The steps listed in the question are part of a best practice framework for implementing a secure BYOD program, which allows employees to use their personal devices to access organizational data and applications. A BYOD program poses significant privacy and security risks, such as data leakage, unauthorized access, malware infection, and compliance violations. Therefore, an organization should follow a comprehensive approach to discover, monitor, manage, and secure the devices, apps, and data involved in a BYOD program. This approach can help the organization meet the GDPR requirements for data protection by design and by default, data security, accountability, and data breach notification. Reference:
Free CIPP/E Study Guide, page 15, section 2.3.3
CIPP/E Certification, page 10, section 1.1.2
Cipp-e Study guides, Class notes & Summaries, document "CIPP/E Exam Summary 2023", page 42, section 2.3.3
NEW QUESTION # 203
In which situation would a data controller most likely be able to justify the processing of the data of a child without parental consent?
- A. When a legitimate business interest makes obtaining consent impractical.
- B. When providing preventive or counselling services to the child.
- C. When the data is to be processed for market research.
- D. When providing the child with materials purely for educational use.
Answer: B
Explanation:
Under the GDPR, the processing of personal data of a child on the basis of consent requires the consent of the holder of parental responsibility over the child, unless the child is at least 16 years old or the applicable national law provides for a lower age (not below 13 years). However, there are some situations where the processing of personal data of a child without parental consent may be justified by other lawful grounds, such as the performance of a contract, the compliance with a legal obligation, the protection of vital interests, the performance of a task carried out in the public interest, or the legitimate interests of the controller or a third party. One of these situations is when the processing is necessary for providing preventive or counselling services to the child, especially in the context of information society services. This is recognised by Recital 38 of the GDPR, which states that:
"Children merit specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned and their rights in relation to the processing of personal data. Such specific protection should, in particular, apply to the use of personal data of children for the purposes of marketing or creating personality or user profiles and the collection of personal data with regard to children when using services offered directly to a child. The consent of the holder of parental responsibility should not be necessary in the context of preventive or counselling services offered directly to a child." Therefore, the processing of personal data of a child without parental consent may be lawful if it is necessary for providing preventive or counselling services to the child, such as health, education, social or legal services, that are offered directly to the child and that aim to protect the child's well-being, safety, development or rights. This may include, for example, online counselling platforms, sexual health advice services, anti-bullying or mental health support services, or child protection helplines. In such cases, the controller should ensure that the processing is fair, transparent, proportionate and respectful of the child's best interests, and that appropriate safeguards are in place to protect the child's personal data and rights.
The other options are not likely to justify the processing of personal data of a child without parental consent, as they do not meet the criteria of necessity, proportionality or legitimacy. The processing of personal data of a child for market research purposes is not necessary for the performance of a contract, the compliance with a legal obligation, the protection of vital interests, the performance of a task carried out in the public interest, or the legitimate interests of the controller or a third party, and may pose significant risks to the child's privacy and autonomy. Therefore, such processing requires the consent of the holder of parental responsibility over the child, unless the child is old enough to give their own consent. The provision of materials purely for educational use to a child may not require the processing of personal data of the child at all, or may only require the processing of minimal personal data, such as the child's name or email address. In such cases, the processing may be based on the consent of the child, if the child is old enough to understand the implications of their consent, or on the legitimate interests of the controller, if the processing is necessary for the provision of the educational materials and does not override the interests or rights of the child. However, the controller should still inform the child and the holder of parental responsibility about the processing and provide them with the opportunity to object or withdraw their consent. The existence of a legitimate business interest does not automatically justify the processing of personal data of a child without parental consent, as the controller must also consider the impact of the processing on the rights and freedoms of the child, and whether the processing is necessary and proportionate for the pursuit of that interest. Moreover, the controller must balance the legitimate business interest against the interests or rights of the child, and ensure that the processing does not cause any harm or disadvantage to the child. If the processing involves the use of personal data of a child for the purposes of marketing or creating personality or user profiles, the controller must obtain the consent of the holder of parental responsibility over the child, unless the child is old enough to give their own consent, as these purposes pose a high risk to the child's privacy and autonomy. References: GDPR Article 6, GDPR Article 8, GDPR Recital 38, Children and the UK GDPR | ICO, Guidelines on consent under Regulation 2016/679 - European Data Protection Board
NEW QUESTION # 204
What obligation does a data controller or processor have after appointing a data protection officer?
- A. To ensure that the data protection officer acts as the sole point of contact for individuals' questions about their personal data.
- B. To ensure that the data protection officer receives sufficient instructions regarding the exercise of his or her defined tasks.
- C. To submit for approval to the data protection officer a code of conduct to govern organizational practices and demonstrate compliance with data protection principles.
- D. To provide resources necessary to carry out the defined tasks of the data protection officer and to maintain his or her expert knowledge.
Answer: C
NEW QUESTION # 205
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