Free IAPP CIPP-E Exam Questions

Question 1

SCENARIO Please use the following to answer the next question: Due to rapidly expanding workforce, Company A has decided to outsource its payroll function to Company B. Company B is an established payroll service provider with a sizable client base and a solid reputation in the industry.

Company B's payroll solution for Company A relies on the collection of time and attendance data obtained via a biometric entry system installed in each of Company A's factories. Company B won't hold any biometric data itself, but the related data will be uploaded to Company B's UK servers and used to provide the payroll service. Company B's live systems will contain the following information for each of Company A's employees:

• Name • Address

• Date of Birth

• Payroll number

• National Insurance number

• Sick pay entitlement

• Maternity/paternity pay entitlement

• Holiday entitlement

• Pension and benefits contributions

• Trade union contributions

Jenny is the compliance officer at Company A. She first considers whether Company A needs to carry out a data protection impact assessment in relation to the new time and attendance system, but isn't sure whether or not this is required.

Jenny does know, however, that under the GDPR there must be a formal written agreement requiring Company B to use the time and attendance data only for the purpose of providing the payroll service, and to apply appropriate technical and organizational security measures for safeguarding the data. Jenny suggests that Company B obtain advice from its data protection officer. The company doesn't have a DPO but agrees, in the interest of finalizing the contract, to sign up for the provisions in full. Company A enters into the contract.

Weeks later, while still under contract with Company A, Company B embarks upon a separate project meant to enhance the functionality of its payroll service, and engages Company C to help. Company C agrees to extract all personal data from Company B's live systems in order to create a new database for Company B. This database will be stored in a test environment hosted on Company C's U.S. server. The two companies agree not to include any data processing provisions in their services agreement, as data is only being used for IT testing purposes.

Unfortunately, Company C's U.S. server is only protected by an outdated IT security system, and suffers a cyber security incident soon after Company C begins work on the project. As a result, data relating to Company A's employees is visible to anyone visiting Company C's website. Company A is unaware of this until Jenny receives a letter from the supervisory authority in connection with the investigation that ensues. As soon as Jenny is made aware of the breach, she notifies all affected employees.

The GDPR requires sufficient guarantees of a company's ability to implement adequate technical and organizational measures. What would be the most realistic way that Company B could have fulfilled this requirement?

A : ring companies whose measures are consistent with recommendations of accrediting bodies.

B : questing advice and technical support from Company A's IT team.

C : oiding the use of another company's data to improve their own services.

D : tting companies' measures with the appropriate supervisory authority.

Answer: A

Question 2

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?

A : Documenting due diligence steps taken in the pre-contractual stage.

B : nducting a risk assessment to analyze possible outsourcing threats.

C : quiring that the processor directly notify the appropriate supervisory authority.

D : intaining evidence that the processor was the best possible market choice available.

Answer: A

Question 3

SCENARIO -

Please use the following to answer the next question:

Gentle Hedgehog Inc. is a privately owned website design agency incorporated in Italy. The company has numerous remote workers in different EU countries. Recently, the management of Gentle Hedgehog noticed a decrease in productivity of their sales team, especially among remote workers. As a result, the company plans to implement a robust but privacy-friendly remote surveillance system to prevent absenteeism, reward top performers, and ensure the best quality of customer service when sales people are interacting with customers.

Gentle Hedgehog eventually hires Sauron Eye Inc., a Chinese vendor of employee surveillance software whose European headquarters is in Germany. Sauron Eye s software provides powerful remote-monitoring capabilities, including 24/7 access to computer cameras and microphones, screen captures, emails, website history, and keystrokes. Any device can be remotely monitored from a central server that is securely installed at Gentle Hedgehog headquarters. The monitoring is invisible by default; however, a so-called Transparent Mode, which regularly and conspicuously notifies all users about the monitoring and its precise scope, also exists. Additionally, the monitored employees are required to use a built-in verification technology involving facial recognition each time they log in.

All monitoring data, including the facial recognition data, is securely stored in Microsoft Azure cloud servers operated by Sauron Eye, which are physically located in France.

What monitoring may be lawfully performed within the scope of Gentle Hedgehog’s business?

A : Everything offered by Sauron Eye's software with the exception of camera and microphone monitoring.

B : Everything offered by Sauron Eye's software, assuming employees provide daily consent to the monitoring

C : Only video calls conducted during business hours and emails that do not contain a “private” or “personal” tag.

D : Only emails, website browsing history and camera for internal video calls that are expressly marked as monitored.

Answer: D

Question 4

A high-ranking employee has his laptop bag stolen in a train station. In addition to the laptop, the bag contained the employee’s ID card, confidential company documents (such as financial information and minutes of board meetings, including participants and their roles), company payment cards, and authorization tokens.

As the company's Data Protection Officer, what should be your first action?

A : Inform the appropriate supervisory authority of the breach.

B : Verify whether the laptop contained personal data and, if so, if it was encrypted.

C : Inform the meeting participants of the breach and provide them with next steps to be taken.

D : Request deactivation of the authorization tokens to avoid access to company data, and remotely wipe the laptop.

Answer: B

Question 5

Start-up company MagicAl is developing an AI system that will be part of a medical device that detects skin cancer. To take measures against potential bias in its AI system, the IT team decides to collect data about users’ ethnic origin, nationality, and gender.Start-up company MagicAl is developing an AI system that will be part of a medical device that detects skin cancer. To take measures against potential bias in its AI system, the IT team decides to collect data about users’ ethnic origin, nationality, and gender.

A : Processing necessary for scientific or statistical purposes.

B : Processing necessary for reasons of substantial public interest.

C : Processing necessary for purposes of preventive or occupational medicine.

D : Processing necessary for the defense of legal claims in potential negligence cases.

Answer: C