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Certified Information Privacy Professional/Europe (CIPP/E) Questions 156–160 (page: 33)

Updated On: 12-Sep-2026

SCENARIO
Please use the following to answer the next question:
WonderkKids provides an online booking service for childcare. WonderKids is based in France, but hosts its website through a company in Switzerland. As part of their service, WonderKids will pass all personal data provided to them to the childcare provider booked through their system. The type of personal data collected on the website includes the name of the person booking the childcare, address and contact details, as well as information about the children to be cared for including name, age, gender and health information. The privacy statement on WonderKids’ website states the following:
“WonderkKids provides the information you disclose to us through this website to your childcare provider for scheduling and health and safety reasons. We may also use your and your child’s personal information for our own legitimate business purposes and we employ a third-party website hosting company located in Switzerland to store the data. Any data stored on equipment located in Switzerland meets the European Commission provisions for guaranteeing adequate safeguards for you and your child’s personal information. We will only share you and your child’s personal information with businesses that we see as adding real value to you. By providing us with any personal data, you consent to its transfer to affiliated businesses and to send you promotional offers.”
“We may retain you and your child’s personal information for no more than 28 days, at which point the data will be depersonalized, unless your personal information is being used for a legitimate business purpose beyond 28 days where it may be retained for up to 2 years.”
“We are processing you and your child’s personal information with your consent. If you choose not to provide certain information to us, you may not be able to use our services. You have the right to: request access to you and your child’s personal information; rectify or erase you or your child’s personal information; the right to correction or erasure of you and/or your child’s personal information; object to any processing of you and your child’s personal information. You also have the right to complain to the supervisory authority about our data processing activities.”
What must the contract between WonderKids and the hosting service provider contain?

  1. The requirement to implement technical and organizational measures to protect the data.
  2. Controller-to-controller model contract clauses.
  3. Audit rights for the data subjects.
  4. A non-disclosure agreement.

Answer(s): B


Reference:

https://gdpr-info.eu/art-46-gdpr/



SCENARIO
Please use the following to answer the next question:
WonderkKids provides an online booking service for childcare. WonderKids is based in France, but hosts its website through a company in Switzerland. As part of their service, WonderKids will pass all personal data provided to them to the childcare provider booked through their system. The type of personal data collected on the website includes the name of the person booking the childcare, address and contact details, as well as information about the children to be cared for including name, age, gender and health information. The privacy statement on WonderKids’ website states the following:
“WonderkKids provides the information you disclose to us through this website to your childcare provider for scheduling and health and safety reasons. We may also use your and your child’s personal information for our own legitimate business purposes and we employ a third-party website hosting company located in Switzerland to store the data. Any data stored on equipment located in Switzerland meets the European Commission provisions for guaranteeing adequate safeguards for you and your child’s personal information. We will only share you and your child’s personal information with businesses that we see as adding real value to you. By providing us with any personal data, you consent to its transfer to affiliated businesses and to send you promotional offers.”
“We may retain you and your child’s personal information for no more than 28 days, at which point the data will be depersonalized, unless your personal information is being used for a legitimate business purpose beyond 28 days where it may be retained for up to 2 years.”
“We are processing you and your child’s personal information with your consent. If you choose not to provide certain information to us, you may not be able to use our services. You have the right to: request access to you and your child’s personal information; rectify or erase you or your child’s personal information; the right to correction or erasure of you and/or your child’s personal information; object to any processing of you and your child’s personal information. You also have the right to complain to the supervisory authority about our data processing activities.”
What direct marketing information can WonderKids send by email without prior consent of the person booking the childcare?

  1. No marketing information at all.
  2. Any marketing information at all.
  3. Marketing information related to other business operations of WonderKids.
  4. Marketing information for products or services similar to those purchased from WonderKids.

Answer(s): D


Reference:

https://gdpr-info.eu/chapter-2/lawfulness-of-processing/



An organization conducts body temperature checks as a part of COVID-19 monitoring. Body temperature is measured manually and is not followed by registration, documentation or other processing of an individual’s personal data.
Which of the following best explain why this practice would

  1. Body temperature is not considered personal data.
  2. The practice does not involve completion by automated means.
  3. Body temperature is considered pseudonymous data.
  4. The practice is for the purpose of alleviating extreme risks to public health.

Answer(s): B


Reference:

https://gdpr-info.eu/issues/pseudonymisation/



When assessing the level of risk created by a data breach, which of the following would

  1. The ease of identification of individuals.
  2. The size of any data processor involved.
  3. The special characteristics of the data controller.
  4. The nature, sensitivity and volume of personal data.

Answer(s): B


Reference:

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



Under Article 80(1) of the GDPR, individuals can elect to be represented by not-for-profit organizations in a privacy group litigation or class action. These organizations are commonly known as?

  1. Law firm organizations.
  2. Civil society organizations.
  3. Human rights organizations.
  4. Constitutional rights organizations.

Answer(s): B


Reference:

https://gdpr-info.eu/art-80-gdpr/



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