IAPP CIPP-E Exam Prep
Certified Information Privacy Professional/Europe (CIPP/E) (Page 11 )

Updated On: 30-Sep-2026

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 Their new manager, Oliver, suspects that this is partly due to the company’s outdated website.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.
With regard to TripBliss Inc.’s use of website cookies, which of the following statements is correct?

  1. Because not all of the cookies are strictly necessary to enable the use of a service requested from TripBliss
    Inc., consent requirements apply to their use of cookies.
  2. Because of the categories of data involved, explicit consent for the use of cookies must be obtained separately from customers.
  3. Because Techiva will receive only aggregate statistics of data collected from the cookies, no additional consent is necessary.
  4. Because the use of cookies involves the potential for location tracking, explicit consent must be obtained from customers.

Answer(s): A


Reference:

https://ec.europa.eu/info/law/law-topic/data-protection/reform/rules-business-and-organisations/



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?

  1. The public
  2. Company X
  3. Law enforcement
  4. The supervisory authority

Answer(s): B


Reference:

https://gdpr-info.eu/art-25-gdpr/



When hiring a data processor, which action would a data controller NOT be able to depend upon to avoid liability in the event of a security breach?

  1. Documenting due diligence steps taken in the pre-contractual stage.
  2. Conducting a risk assessment to analyze possible outsourcing threats.
  3. Requiring that the processor directly notifies the appropriate supervisory authority.
  4. Maintaining evidence that the processor was the best possible market choice available.

Answer(s): C



WP29’s “Guidelines on Personal data breach notification under Regulation 2016/679’’ provides examples of ways to communicate data breaches transparently.
Which of the following was listed as a method that would NOT be effective for communicating a breach to data subjects?

  1. A postal notification
  2. A direct electronic message
  3. A notice on a corporate blog
  4. A prominent advertisement in print media

Answer(s): D


Reference:

https://gdpr-info.eu/art-34-gdpr/



Which of the following would require designating a data protection officer?

  1. Processing is carried out by an organization employing 250 persons or more.
  2. Processing is carried out for the purpose of providing for-profit goods or services to individuals in the EU.
  3. The core activities of the controller or processor consist of processing operations of financial information or information relating to children.
  4. The core activities of the controller or processor consist of processing operations that require systematic monitoring of data subjects on a large scale.

Answer(s): D


Reference:

https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/accountability-and-governance/data-protection-officers/



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