IAPP CIPP-E Exam Prep
Certified Information Privacy Professional/Europe (CIPP/E) (Page 10 )

Updated On: 30-Sep-2026

Assuming that the “without undue delay” provision is followed, what is the time limit for complying with a data access request?

  1. Within 40 days of receipt
  2. Within 40 days of receipt, which may be extended by up to 40 additional days
  3. Within one month of receipt, which may be extended by up to an additional month
  4. Within one month of receipt, which may be extended by an additional two months

Answer(s): B


Reference:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-of-access/



A U.S.-based online shop uses sophisticated software to track the browsing behavior of its European customers and predict future purchases. It also shares this information with third parties. Under the GDPR, what is the online shop’s PRIMARY obligation while engaging in this kind of profiling?

  1. It must solicit informed consent through a notice on its website
  2. It must seek authorization from the European supervisory authorities
  3. It must be able to demonstrate a prior business relationship with the customers
  4. It must prove that it uses sufficient security safeguards to protect customer data

Answer(s): A


Reference:

https://gdpr-info.eu/art-22-gdpr/



Which of the following would NOT be relevant when determining if a processing activity would be considered profiling?

  1. If the processing is to be performed by a third-party vendor
  2. If the processing involves data that is considered personal data
  3. If the processing of the data is done through automated means
  4. If the processing is used to predict the behavior of data subjects

Answer(s): A


Reference:

https://gdpr-info.eu/art-4-gdpr/



Under Article 21 of the GDPR, a controller must stop profiling when requested by a data subject, unless it can demonstrate compelling legitimate grounds that override the interests of the individual. In the Guidelines on Automated individual decision-making and Profiling, the WP 29 says the controller needs to do all of the following to demonstrate that it has such legitimate grounds EXCEPT?

  1. Carry out an exercise that weighs the interests of the controller and the basis for the data subject’s objection.
  2. Consider the impact of the profiling on the data subject’s interest, rights and freedoms.
  3. Demonstrate that the profiling is for the purposes of direct marketing.
  4. Consider the importance of the profiling to their particular objective.

Answer(s): C


Reference:

https://gdpr-info.eu/art-21-gdpr/



SCENARIO
Please use the following to answer the next question:
TripBliss Inc. is a travel service company which has lost substantial revenue over the last few years. Their new manager, Oliver, suspects that this is partly due to the company’s outdated website. After doing some research, he meets with a sales representative from the up-and-coming IT company Techiva, hoping that they can design a new, cutting-edge website for TripBliss Inc.’s foundering business.
During negotiations, a Techiva representative describes a plan for gathering more customer information through detailed questionnaires, which could be used to tailor their preferences to specific travel destinations.
TripBliss Inc. can choose any number of data categories – age, income, ethnicity – that would help them best accomplish their goals. Oliver loves this idea, but would also like to have some way of gauging how successful this approach is, especially since the questionnaires will require customers to provide explicit consent to having their data collected. The Techiva representative suggests that they also run a program to analyze the new website’s traffic, in order to get a better understanding of how customers are using it. He explains his plan to place a number of cookies on customer devices. The cookies will allow the company to collect IP addresses and other information, such as the sites from which the customers came, how much time they spend on the TripBliss Inc. website, and which pages on the site they visit. All of this information will be compiled in log files, which Techiva will analyze by means of a special program. TripBliss Inc. would receive aggregate statistics to help them evaluate the website’s effectiveness. Oliver enthusiastically engages Techiva for these services.
Techiva assigns the analytics portion of the project to longtime account manager Leon Santos. As is standard practice, Leon is given administrator rights to TripBliss Inc.’s website, and can authorize access to the log files gathered from it. Unfortunately for TripBliss Inc., however, Leon is taking on this new project at a time when his dissatisfaction with Techiva is at a high point. In order to take revenge for what he feels has been unfair treatment at the hands of the company, Leon asks his friend Fred, a hobby hacker, for help. Together they come up with the following plan: Fred will hack into Techiva’s system and copy their log files onto a USB stick. Despite his initial intention to send the USB to the press and to the data protection authority in order to denounce Techiva, Leon experiences a crisis of conscience and ends up reconsidering his plan. He decides instead to securely wipe all the data from the USB stick and inform his manager that the company’s system of access control must be reconsidered.
If TripBliss Inc. decides not to report the incident to the supervisory authority, what would be their BEST defense?

  1. The resulting obligation to notify data subjects would involve disproportionate effort.
  2. The incident resulted from the actions of a third-party that were beyond their control.
  3. The destruction of the stolen data makes any risk to the affected data subjects unlikely.
  4. The sensitivity of the categories of data involved in the incident was not substantial enough.

Answer(s): C


Reference:

https://gdpr-info.eu/art-6-gdpr/



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