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IAPP CIPP-E Exam Questions
Certified Information Privacy Professional/Europe (CIPP/E) (Page 8 )

Updated On: 18-Apr-2026
Page 7 of 38
PDF with 295 Questions

When collecting personal data in a European Union (EU) member state, what must a company do if it collects personal data from a source other than the data subjects themselves?

  1. Inform the subjects about the collection
  2. Provide a public notice regarding the data
  3. Upgrade security to match that of the source
  4. Update the data within a reasonable timeframe

Answer(s): A

Explanation:

According to Article 14 of the GDPR, when a controller collects personal data from a source other than the data subject, the controller must provide the data subject with certain information, such as the identity and contact details of the controller, the purposes and legal basis of the processing, the categories of personal data concerned, the recipients or categories of recipients of the personal data, and the rights of the data subject. This information must be provided within a reasonable period after obtaining the personal data, but at the latest within one month, or at the time of the first communication with the data subject, or before disclosing the data to another recipient. The purpose of this provision is to ensure fair and transparent processing of personal data and to respect the right of the data subject to be informed.


Reference:

Article 14 of the GDPR, which specifies the information to be provided where personal data have not been obtained from the data subject.
ICO guidance, which explains the requirements and exceptions of Article 14 of the GDPR. EDPB guidelines, which provide further guidance on the application of Article 14 of the GDPR.



Under the GDPR, which essential pieces of information must be provided to data subjects before collecting their personal data?

  1. The authority by which the controller is collecting the data and the third parties to whom the data will be sent.
  2. The name/s of relevant government agencies involved and the steps needed for revising the data.
  3. The identity and contact details of the controller and the reasons the data is being collected.
  4. The contact information of the controller and a description of the retention policy.

Answer(s): C

Explanation:

The GDPR requires that data subjects are provided with certain information when their personal data are collected, either from the data subject themselves or from another source12. This information includes, among other things, the identity and contact details of the controller (and, where applicable, of the controller's representative and the data protection officer), and the purposes of the processing for which the personal data are intended as well as the legal basis for the processing34. This information is necessary to ensure fair and transparent processing of personal data, and to enable data subjects to exercise their rights under the GDPR5. Therefore, option C is the correct answer, as it contains two of the essential pieces of information that must be provided to data subjects before collecting their personal data. Options A, B and D are incorrect, as they do not include all the required information or include information that is not mandatory.


Reference:

1: Article 13 of the GDPR
2: Article 14 of the GDPR
3: Article 13(1)(a) and © of the GDPR
4: Article 14(1)(a) and © of the GDPR
5: Recital 60 of the GDPR

https://gdpr-info.eu/art-13-gdpr/



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): D

Explanation:

According to the GDPR, data controllers must respond to a data access request (also known as a subject access request or SAR) without undue delay and in any event within one month of receipt of the request. This time limit can be extended by a further two months if the request is complex or if the controller receives a number of requests from the same individual. However, the controller must still inform the individual within one month of receipt of the request and explain why the extension is necessary. The time limit is calculated from the day after the request is received (whether it is a working day or not) until the corresponding calendar date in the next month. If there is no corresponding calendar date, the deadline is the last day of the next month. If the deadline falls on a weekend or public holiday, the response must be provided on the next working day.


Reference:

GDPR, Article 12(3)
ICO, Right of access1
ICO, Time limits for responding to data protection rights requests2

https://ico.org.uk/for-organisations/guide-to-data-protection/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

Explanation:

The GDPR defines profiling as any form of automated processing of personal data to evaluate certain personal aspects relating to a natural person, such as their preferences, behaviour, or interests1. Profiling is subject to the general principles and rules of the GDPR, such as lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality2. The GDPR also provides specific rights for data subjects who are subject to profiling, such as the right to be informed, the right to access, the right to rectify, the right to object, and the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects on them3. In the given scenario, the online shop is engaging in profiling by tracking the browsing behaviour of its European customers and predicting future purchases. It is also sharing this information with third parties, which may involve further processing of the personal data. Therefore, the online shop must comply with the GDPR requirements for profiling and ensure that it has a valid legal basis for the processing. According to Article 6 of the GDPR, there are six possible legal bases for processing personal data: consent, contract, legal obligation, vital interests, public interest, or legitimate interests4. However, not all of them are equally applicable or appropriate for profiling activities, especially when they involve sensitive or special categories of data, such as biometric, genetic, or health data, which require additional safeguards under Article 9 of the GDPR5. In this case, the most relevant and suitable legal basis for the online shop's profiling is consent, which means that the data subject has given a clear and affirmative indication of their agreement to the processing of their personal data for one or more specific purposes6. Consent must be freely given, specific, informed, and unambiguous, and must be obtained before the processing begins7. The online shop must also inform the data subject about the nature and purpose of the profiling, the logic involved, the consequences, and the rights they have in relation to it. The online shop must also respect the data subject's right to withdraw their consent at any time and to object to the profiling. Therefore, the online shop's primary obligation while engaging in this kind of profiling is to solicit informed consent through a notice on its website, which must be clear, concise, and easily accessible, and must not be bundled with other terms and conditions. The online shop must also provide a simple and effective mechanism for the data subject to give or revoke their consent, such as a checkbox, a slider, or a button. The online shop must also keep records of the consent obtained and be able to demonstrate that it has complied with the GDPR requirements for consent. The other options (B, C, and D) are not the primary obligation for the online shop, as they are either irrelevant or insufficient for the GDPR compliance. Seeking authorization from the European supervisory authorities is not necessary, unless the online shop is involved in a cross-border processing that requires a prior consultation under Article 36 of the GDPR. Demonstrating a prior business relationship with the customers is not a valid legal basis for the profiling, as it does not imply consent or legitimate interests. Proving that it uses sufficient security safeguards to protect customer data is a general obligation for any processing of personal data, but it does not address the specific issues and risks of profiling, such as discrimination, manipulation, or loss of
control.


Reference:

1: What is automated individual decision-making and profiling?
2: Article 5 of the GDPR
3: Rights related to automated decision making including profiling
4: [Regulation (EU)
of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive
/EC (General Data Protection Regulation)]
5: Article 9 of the GDPR
6: Article 4 (11) of the GDPR
7: Article 7 of the GDPR
: Article 13 and 14 of the GDPR
: Article 21 of the GDPR
: Article 12 of the GDPR
: [Guidelines on consent under Regulation
]
: Article 24 of the GDPR
: Article 36 of the GDPR
: [Guidelines on Automated individual decision-making and Profiling for the purposes of Regulation
]
: [https://edpb.europa.eu/sites/edpb/files/files/file1/edpb_guidelines_202005_consent_en.pdf] : [https://edpb.europa.eu/sites/edpb/files/files/file1/20171104_wp251rev01_en.pdf]



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

Explanation:

The GDPR defines profiling as any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements12. Therefore, the relevant factors when determining if a processing activity would be considered profiling are:
whether the processing involves data that is considered personal data; whether the processing of the data is done through automated means; and whether the processing is used to predict the behavior of data subjects. The identity of the processor, whether it is the controller or a third-party vendor, is not relevant for the definition of profiling. However, it may have implications for the accountability and responsibility of the parties involved, as well as the data protection rights of the data subjects34.


Reference:

CIPP/E Certification - International Association of Privacy Professionals, Free CIPP/E Study Guide - International Association of Privacy Professionals, GDPR - EUR-Lex, What is automated individual decision-making and profiling? | ICO, WP29 releases guidelines on profiling under the GDPR, UK: A Guide To GDPR Profiling And Automated Decision-Making - Mondaq



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

Explanation:

According to the UK GDPR, the data subject has the right to object, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions1. The controller must stop the processing unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims1. The WP 29 Guidelines on Automated individual decision-making and Profiling provide some guidance on how to assess the existence of such compelling legitimate grounds2. The controller needs to carry out an exercise that weighs the interests of the controller and the basis for the data subject's objection, consider the impact of the profiling on the data subject's interest, rights and freedoms, and consider the importance of the profiling to their particular objective2. However, the controller does not need to demonstrate that the profiling is for the purposes of direct marketing, as this is a separate ground for objection under Article 21(2) of the UK GDPR, which gives the data subject an absolute right to object to such processing13. Therefore, option C is the correct answer, as it is not required by the controller to demonstrate that it has compelling legitimate grounds for profiling.


Reference:

132
https://gdpr.eu/article-21-right-to-object/ https://ico.org.uk/for-organisations-2/guide-to-data-

protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-object/

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 Questionaires, 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 Questionaires 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

Explanation:

According to the GDPR, data controllers must report personal data breaches to the supervisory authority without undue delay and, where feasible, not later than 72 hours after having become aware of it (Art 33 of GDPR). However, the notification is not required if the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons (Art 33(1) of GDPR). In this case, TripBliss Inc. could argue that the stolen data was securely erased by Leon before it could be disclosed to anyone else, and therefore the risk of harm to the data subjects was minimal. TripBliss Inc. would have to provide evidence of the secure deletion of the data and the absence of any copies or backups. Alternatively, TripBliss Inc. could also invoke the exception of disproportionate effort to avoid notifying the data subjects directly, but only if they have made a public communication or similar measure to inform them in an equally effective manner (Art 34(3)(b) of GDPR). The other options are not valid defenses, as they do not affect the likelihood of risk to the data subjects. The incident was not caused by a third-party, but by an employee of Techiva, who was acting as a data processor on behalf of TripBliss Inc. As the data controller, TripBliss Inc. is responsible for ensuring that the data processor provides sufficient guarantees to implement appropriate technical and organisational measures to comply with the GDPR (Art 28 of GDPR). The sensitivity of the data categories is not relevant for the notification obligation, as any personal data breach could pose a risk to the data subjects, depending on the circumstances. The GDPR does not provide a threshold for the sensitivity of the data, but rather requires a case-by-case assessment of the potential impact of the breach.


Reference:

GDPR, Art 33, Art 34, Art 28
Free CIPP/E Study Guide, p. 15
European Data Protection Law & Practice, p. 123-124
Personal data breach notification under the 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 Questionaires, 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 Questionaires 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

Explanation:

According to the ePrivacy Directive (2002/58/EC), the use of cookies or similar devices that store or access information on the user's device requires the user's consent, unless the cookie is strictly necessary to enable the use of a service requested by the user. For example, a cookie that remembers the items in a shopping cart does not require consent, but a cookie that tracks the user's browsing behavior for analytics or advertising purposes does. The consent must be freely given, specific, informed, and unambiguous, and can be obtained through appropriate settings of the browser or other application. The consent must also be separate from other consents, such as the consent to the processing of personal data. The categories of data involved or the recipients of the data do not affect the consent requirement for the use of cookies. The consent must also be obtained before the cookie is placed or accessed, unless the cookie is exempted. Therefore, option A is correct.
Option B is incorrect because explicit consent is not required for the use of cookies, unless the cookie also involves the processing of special categories of personal data under the GDPR. However, in this scenario, there is no indication that the cookies collect or process such data. Therefore, option B is incorrect.
Option C is incorrect because the consent requirement for the use of cookies does not depend on the recipients of the data or the level of aggregation of the data. The consent must be obtained from the user whose device is accessed or stored by the cookie, regardless of who receives the data or how it is processed. Therefore, option C is incorrect.
Option D is incorrect because the consent requirement for the use of cookies does not depend on the potential for location tracking. The consent must be obtained for any cookie that is not strictly necessary to enable the use of a service requested by the user, regardless of the type or purpose of the cookie. Therefore, option D is incorrect.


Reference:

ePrivacy Directive, Article 5(3)
GDPR, Article 4(11), Article 7, Article 9
CIPP/E Study Guide, Chapter 5, Section 5.2.2



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