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Certified Information Privacy Professional/Europe (CIPP/E) Questions 161–165 (page: 34)

Updated On: 12-Sep-2026

SCENARIO Please use the following to answer the next question:
BHealthy, a company based in Italy, is ready to launch a new line of natural products, with a focus on sunscreen. The last step prior to product launch is for BHealthy to conduct research to decide how extensively to market its new line of sunscreens across Europe. To do so, BHealthy teamed up with Natural Insight, a company specializing in determining pricing for natural products. BHealthy decided to share its existing customer information – name, location, and prior purchase history – with Natural Insight. Natural Insight intends to use this information to train its algorithm to help determine the price point at which BHealthy can sell its new sunscreens.
Prior to sharing its customer list, BHealthy conducted a review of Natural Insight’s security practices and concluded that the company has sufficient security measures to protect the contact information. Additionally, BHealthy’s data processing contractual terms with Natural Insight require continued implementation of technical and organization measures. Also indicated in the contract are restrictions on use of the data provided by BHealthy for any purpose beyond provision of the services, which include use of the data for continued improvement of Natural Insight’s machine learning algorithms.
What is the nature of BHealthy and Natural Insight’s relationship?

  1. Natural Insight is BHealthy’s processor because the companies entered into data processing terms.
  2. Natural Insight is BHealthy’s processor because BHealthy is sharing its customer information with Natural
    Insight.
  3. Natural Insight is the controller because it determines the security measures to implement to protect data it processes; BHealthy is a co-controller because it engaged Natural Insight to determine pricing for the new sunscreens.
  4. Natural Insight is a controller because it is separately determining the purpose of processing when it uses
    BHealthy’s customer information to improve its machine learning algorithms.

Answer(s): D



SCENARIO Please use the following to answer the next question:
BHealthy, a company based in Italy, is ready to launch a new line of natural products, with a focus on sunscreen. The last step prior to product launch is for BHealthy to conduct research to decide how extensively to market its new line of sunscreens across Europe. To do so, BHealthy teamed up with Natural Insight, a company specializing in determining pricing for natural products. BHealthy decided to share its existing customer information – name, location, and prior purchase history – with Natural Insight. Natural Insight intends to use this information to train its algorithm to help determine the price point at which BHealthy can sell its new sunscreens.
Prior to sharing its customer list, BHealthy conducted a review of Natural Insight’s security practices and concluded that the company has sufficient security measures to protect the contact information. Additionally, BHealthy’s data processing contractual terms with Natural Insight require continued implementation of technical and organization measures. Also indicated in the contract are restrictions on use of the data provided by BHealthy for any purpose beyond provision of the services, which include use of the data for continued improvement of Natural Insight’s machine learning algorithms.
Under the GDPR, what are Natural Insight’s security obligations with respect to the customer information it received from BHealthy?

  1. Appropriate security that takes into account the industry practices for protecting customer contact information and purchase history.
  2. Only the security measures assessed by BHealthy prior to entering into the data processing contract.
  3. Absolute security since BHealthy is sharing personal data, including purchase history, with Natural Insight.
  4. The level of security that a reasonable data subject whose data is processed would expect in relation to the data subject’s purchase history.

Answer(s): D


Reference:

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



SCENARIO Please use the following to answer the next question:
BHealthy, a company based in Italy, is ready to launch a new line of natural products, with a focus on sunscreen. The last step prior to product launch is for BHealthy to conduct research to decide how extensively to market its new line of sunscreens across Europe. To do so, BHealthy teamed up with Natural Insight, a company specializing in determining pricing for natural products. BHealthy decided to share its existing customer information – name, location, and prior purchase history – with Natural Insight. Natural Insight intends to use this information to train its algorithm to help determine the price point at which BHealthy can sell its new sunscreens.
Prior to sharing its customer list, BHealthy conducted a review of Natural Insight’s security practices and concluded that the company has sufficient security measures to protect the contact information. Additionally, BHealthy’s data processing contractual terms with Natural Insight require continued implementation of technical and organization measures. Also indicated in the contract are restrictions on use of the data provided by BHealthy for any purpose beyond provision of the services, which include use of the data for continued improvement of Natural Insight’s machine learning algorithms.
In which case would Natural Insight’s use of BHealthy’s data for improvement of its algorithms be considered data processor activity?

  1. If Natural Insight uses BHealthy’s data for improving price point predictions only for BHealthy.
  2. If Natural Insight receives express contractual instructions from BHealthy to use its data for improving its algorithms.
  3. If Natural Insight agrees to be fully liable for its use of BHealthy’s customer information in its product improvement activities.
  4. If Natural Insight satisfies the transparency requirement by notifying BHealthy’s customers of its plans to use their information for its product improvement activities.

Answer(s): B


Reference:

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



Which of the following is

  1. The right to request access to the personal data a controller holds about them.
  2. The right to request the deletion of data a controller holds about them.
  3. The right to opt-out of the sale of their personal data to third parties.
  4. The right to request restriction of processing of personal data, under certain scenarios.

Answer(s): C


Reference:

https://gdpr-info.eu/chapter-3/



As per the GDPR, which legal basis would be the most appropriate for an online shop that wishes to process personal data for the purpose of fraud prevention?

  1. Protection of the interests of the data subjects.
  2. Performance of a contact
  3. Legitimate interest
  4. Consent

Answer(s): C


Reference:

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



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