Free IAPP CIPP-E Exam Questions

Question 1

Through a combination of hardware failure and human error, the decryption key for a bank’s customer account transaction database has been lost. An investigation has determined that this was not the result of hacking or malfeasance, simply an unfortunate combination of circumstances. Which of the following accurately indicates the nature of this incident?

A : A data breach has not occurred because the loss was not the result of hacking.

B : A data breach has not occurred because no data was exposed to any unauthorized individual.

C : A data breach has occurred because the loss of the key has resulted in the data no longer being accessible.

D : A data breach has occurred because the loss of the key has resulted in the loss of confidentiality or integrity of the data.

Answer: D

Question 2

SCENARIO

Please use the following to answer the next question:

The fitness company Vigotron has recently developed a new app called M-Health, which it wants to market on its website as a free download. Vigotron's marketing manager asks his assistant Emily to create a webpage that describes the app and specifies the terms of use. Emily, who is new at Vigotron, is excited about this task. At her previous job she took a data protection class, and though the details are a little hazy, she recognizes that Vigotron is going to need to obtain user consent for use of the app in some cases. Emily sketches out the following draft, trying to cover as much as possible before sending it to Vigotron's legal department.

Registration Form

Vigotron's new M-Health app makes it easy for you to monitor a variety of health-related activities, including diet, exercise, and sleep patterns. M-Health relies on your smartphone settings (along with other third-party apps you may already have) to collect data about all of these important lifestyle elements, and provide the information necessary for you to enrich your quality of life. (Please click here to read a full description of the services that M-Health provides.)

Vigotron values your privacy. The M-Heaith app allows you to decide which information is stored in it, and which apps can access your data. When your device is locked with a passcode, all of your health and fitness data is encrypted with your passcode. You can back up data stored in the Health app to Vigotron's cloud provider, Stratculous. (Read more about Stratculous here.)

Vigotron will never trade, rent or sell personal information gathered from the M-Health app. Furthermore, we will not provide a customer's name, email address or any other information gathered from the app to any third-party without a customer's consent, unless ordered by a court, directed by a subpoena, or to enforce the manufacturer's legal rights or protect its business or property.

We are happy to offer the M-Health app free of charge. If you want to download and use it, we ask that you first complete this registration form. (Please note that use of the M-Health app is restricted to adults aged 16 or older, unless parental consent has been given to minors intending to use it.)

• First name:

• Surname:

• Year of birth:

• Email:

• Physical Address (optional']:

• Health status:

if you are interested in receiving newsletters about our products and services that we think may be of interest to you, please include your physical address. If you decide later that you do not wish to receive these newsletters, you can unsubscribe by sending an email to unsubscribe@vigotron.com or send a letter with your request to the address listed at the bottom of this page.

Terms and Conditions

1. Jurisdiction. [...] 2. Applicable law. [...] 3. Limitation of liability. [...]

Consent

By completing this registration form, you attest that you are at least 16 years of age, and that you consent to the processing of your personal data by Vigotron for the purpose of using the M-Health app. Although you are entitled to opt out of any advertising or marketing, you agree that Vigotron may contact you or provide you with any required notices, agreements, or other information concerning the services by email or other electronic means. You also agree that the Company may send automated emails with alerts regarding any problems with the M-Health app that may affect your well being.

Emily sends the draft to Sam for review. Which of the following is Sam most likely to point out as the biggest problem with Emily's consent provision?

A : is not legal to include fields requiring information regarding health status without consent

B : ocessing health data requires explicit consent, but the form does not ask for explicit consent.

C : Direct marketing requires explicit consent, whereas the registration form only provides for a right to object

D : provision of the fitness app should be made conditional on the consent to the data processing for direct marketing.

Answer: C

Question 3

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 4

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

Question 5

SCENARIO -

Please use the following to answer the next question:

Financially, it has been a very good year at ARRA Hotels: Their 21 hotels, located in Greece (5), Italy (15) and Spain (1), have registered their most profitable results ever. To celebrate this achievement, ARRA Hotels' Human Resources office, based in ARRA's main Italian establishment, has organized a team event for its 420 employees and their families at its hotel in Spain.

Upon arrival at the hotel, each employee and family member is given an electronic wristband at the reception desk. The wristband serves a number of functions:

• Allows access to the "party zone" of the hotel, and emits a buzz if the user approaches any unauthorized areas

• Allows up to three free drinks for each person of legal age, and emits a buzz once this limit has been reached

• Grants a unique ID number for participating in the games and contests that have been planned.

Along with the wristband, each guest receives a QR code that leads to the online privacy notice describing the use of the wristband. The page also contains an unchecked consent checkbox. In the case of employee family members under the age of 16, consent must be given by a parent.

Among the various activities planned for the event, ARRA Hotels' HR office has autonomously set up a photocall area, separate from the main event venue, where employees can come and have their pictures taken in traditional carnival costume. The photos will be posted on ARRA Hotels' main website for general marketing purposes.

On the night of the event, an employee from one of ARRA's Greek hotels is displeased with the results of the photos in which he appears. He intends to file a complaint with the relevant supervisory authority in regard to the following:

• The lack of any privacy notice in the separate photocall area

• The unlawful cross-border processing of his personal data

• The unacceptable aesthetic outcome of his photos

Which of the following is NOT necessarily considered a factor in identifying whether the processing could be considered a "cross-border processing"?

A : The total number of the data subjects interested.

B : The potential harm for the data subjects affected.

C : The limitation of rights of the data subjects concerned.

D : The exposure of the information of the data subjects involved.

Answer: A