[Jan 16, 2022] New CIPP-E Exam Dumps with High Passing Rate
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NEW QUESTION 32
What type of data lies beyond the scope of the General Data Protection Regulation?
- A. Pseudonymized
- B. Anonymized
- C. Encrypted
- D. Masked
Answer: B
NEW QUESTION 33
SCENARIO
Please use the following to answer the next question:
Joe started the Gummy Bear Company in 2000 from his home in Vermont, USA.
Today, it is a multi-billion-dollar candy company operating in every continent. All of the company's IT servers are located in Vermont. This year Joe hires his son Ben to join the company and head up Project Big, which is a major marketing strategy to triple gross revenue in just 5 years. Ben graduated with a PhD in computer software from a top university. Ben decided to join his father's company, but is also secretly working on launching a new global online dating website company called Ben Knows Best.
Ben is aware that the Gummy Bear Company has millions of customers and believes that many of them might also be interested in finding their perfect match. For Project Big, Ben redesigns the company's online web portal and requires customers in the European Union and elsewhere to provide additional personal information in order to remain a customer. Project Ben begins collecting data about customers' philosophical beliefs, political opinions and marital status.
If a customer identifies as single, Ben then copies all of that customer's personal data onto a separate database for Ben Knows Best. Ben believes that he is not doing anything wrong, because he explicitly asks each customer to give their consent by requiring them to check a box before accepting their information. As Project Big is an important project, the company also hires a first year college student named Sam, who is studying computer science to help Ben out.
Ben calls out and Sam comes across the Ben Knows Best database. Sam is planning on going to Ireland over Spring Beak with 10 of his friends, so he copies all of the customer information of people that reside in Ireland so that he and his friends can contact people when they are in Ireland.
Joe also hires his best friend's daughter, Alice, who just graduated from law school in the U.S., to be the company's new General Counsel. Alice has heard about the GDPR, so she does some research on it. Alice approaches Joe and informs him that she has drafted up Binding Corporate Rules for everyone in the company to follow, as it is important for the company to have in place a legal mechanism to transfer data internally from the company's operations in the European Union to the U.S.
Joe believes that Alice is doing a great job, and informs her that she will also be in-charge of handling a major lawsuit that has been brought against the company in federal court in the U.S. To prepare for the lawsuit, Alice instructs the company's IT department to make copies of the computer hard drives from the entire global sales team, including the European Union, and send everything to her so that she can review everyone's information. Alice believes that Joe will be happy that she did the first level review, as it will save the company a lot of money that would otherwise be paid to its outside law firm.
In preparing the company for its impending lawsuit, Alice's instruction to the company's IT Department violated Article 5 of the GDPR because the company failed to first do what?
- A. Inform all of its employees about the lawsuit.
- B. Send out consent forms to all of its employees.
- C. Encrypt the data from all of its employees.
- D. Minimize the amount of data collected for the lawsuit.
Answer: D
NEW QUESTION 34
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.
After Leon has informed his manager, what is Techiva's legal responsibility as a processor?
- A. They must report it to TripBliss Inc.
- B. They must conduct a full systems audit.
- C. They must report it to the supervisory authority.
- D. They must inform customers who have used the website.
Answer: B
NEW QUESTION 35
SCENARIO
Please use the following to answer the next question:
Building Block Inc. is a multinational company, headquartered in Chicago with offices throughout the United States, Asia, and Europe (including Germany, Italy, France and Portugal). Last year the company was the victim of a phishing attack that resulted in a significant data breach. The executive board, in coordination with the general manager, their Privacy Office and the Information Security team, resolved to adopt additional security measures. These included training awareness programs, a cybersecurity audit, and use of a new software tool called SecurityScan, which scans employees' computers to see if they have software that is no longer being supported by a vendor and therefore not getting security updates. However, this software also provides other features, including the monitoring of employees' computers.
Since these measures would potentially impact employees, Building Block's Privacy Office decided to issue a general notice to all employees indicating that the company will implement a series of initiatives to enhance information security and prevent future data breaches.
After the implementation of these measures, server performance decreased. The general manager instructed the Security team on how to use SecurityScan to monitor employees' computers activity and their location.
During these activities, the Information Security team discovered that one employee from Italy was daily connecting to a video library of movies, and another one from Germany worked remotely without authorization.
The Security team reported these incidents to the Privacy Office and the general manager. In their report, the team concluded that the employee from Italy was the reason why the server performance decreased.
Due to the seriousness of these infringements, the company decided to apply disciplinary measures to both employees, since the security and privacy policy of the company prohibited employees from installing software on the company's computers, and from working remotely without authorization.
In addition to notifying employees about the purpose of the monitoring, the potential uses of their data and their privacy rights, what information should Building Block have provided them before implementing the security measures?
- A. Information about how providing consent could affect them as employees.
- B. Information about what is specified in the employment contract.
- C. Information about how the measures are in the best interests of the company.
- D. Information about who employees should contact with any queries.
Answer: B
NEW QUESTION 36
In which of the following cases, cited as an example by a WP29 guidance, would conducting a single data protection impact assessment to address multiple processing operations be allowed?
- A. A marketing team that wants to collect mailing addresses of customers for whom they already have email addresses.
- B. A railway operator who plans to evaluate the same video surveillance in all the train stations of his company.
- C. A data controller who plans to use a new technology product that has already undergone a DPIA by the product's provider.
- D. A medical organization that wants to begin genetic testing to support earlier research for which they have performed a DPIA.
Answer: B
NEW QUESTION 37
SCENARIO
Please use the following to answer the next question:
Brady is a computer programmer based in New Zealand who has been running his own business for two years. Brady's business provides a low-cost suite of services to customers throughout the European Economic Area (EEA). The services are targeted towards new and aspiring small business owners. Brady's company, called Brady Box, provides web page design services, a Social Networking Service (SNS) and consulting services that help people manage their own online stores.
Unfortunately, Brady has been receiving some complaints. A customer named Anna recently uploaded her plans for a new product onto Brady Box's chat area, which is open to public viewing. Although she realized her mistake two weeks later and removed the document, Anna is holding Brady Box responsible for not noticing the error through regular monitoring of the website. Brady believes he should not be held liable.
Another customer, Felipe, was alarmed to discover that his personal information was transferred to a third- party contractor called Hermes Designs and worries that sensitive information regarding his business plans may be misused. Brady does not believe he violated European privacy rules. He provides a privacy notice to all of his customers explicitly stating that personal data may be transferred to specific third parties in fulfillment of a requested service. Felipe says he read the privacy notice but that it was long and complicated Brady continues to insist that Felipe has no need to be concerned, as he can personally vouch for the integrity of Hermes Designs. In fact, Hermes Designs has taken the initiative to create sample customized banner advertisements for customers like Felipe. Brady is happy to provide a link to the example banner ads, now posted on the Hermes Designs webpage. Hermes Designs plans on following up with direct marketing to these customers.
Brady was surprised when another customer, Serge, expressed his dismay that a quotation by him is being used within a graphic collage on Brady Box's home webpage. The quotation is attributed to Serge by first and last name. Brady, however, was not worried about any sort of litigation. He wrote back to Serge to let him know that he found the quotation within Brady Box's Social Networking Service (SNS), as Serge himself had posted the quotation. In his response, Brady did offer to remove the quotation as a courtesy.
Despite some customer complaints, Brady's business is flourishing. He even supplements his income through online behavioral advertising (OBA) via a third-party ad network with whom he has set clearly defined roles. Brady is pleased that, although some customers are not explicitly aware of the OBA, the advertisements contain useful products and services.
Under the General Data Protection Regulation (GDPR), what is the most likely reason Serge may have grounds to object to the use of his quotation?
- A. Because of the juxtaposition of the quotation with others' quotations.
- B. Because of the misapplication of the household exception in relation to a social networking service (SNS).
- C. Because of the use of personal data outside of the social networking service (SNS).
- D. Because of the misrepresentation of personal data as an endorsement.
Answer: B
NEW QUESTION 38
Which GDPR requirement will present the most significant challenges for organizations with Bring Your Own Device (BYOD) programs?
- A. Personal data of data subjects must always be accurate and kept up to date.
- B. Processing of special categories of personal data on a large scale requires appointing a DPO.
- C. Data controllers must be in control of the data they hold at all times.
- D. Data subjects must be sufficiently informed of the purposes for which their personal data is processed.
Answer: C
NEW QUESTION 39
Tanya is the Data Protection Officer for Curtains Inc., a GDPR data controller. She has recommended that the company encrypt all personal data at rest. Which GDPR principle is she following?
- A. Integrity and confidentiality
- B. Storage Limitation
- C. Lawfulness, fairness and transparency
- D. Accuracy
Answer: A
NEW QUESTION 40
SCENARIO
Please use the following to answer the next question:
T-Craze, a German-headquartered specialty t-shirt company, was successfully selling to large German metropolitan cities. However, after a recent merger with another German-based company that was selling to a broader European market, T-Craze revamped its marketing efforts to sell to a wider audience. These efforts included a complete redesign of its logo to reflect the recent merger, and improvements to its website meant to capture more information about visitors through the use of cookies.
T-Craze also opened various office locations throughout Europe to help expand its business. While Germany continued to host T-Craze's headquarters and main product-design office, its French affiliate became responsible for all marketing and sales activities. The French affiliate recently procured the services of Right Target, a renowned marketing firm based in the Philippines, to run its latest marketing campaign. After thorough research, Right Target determined that T-Craze is most successful with customers between the ages of 18 and 22. Thus, its first campaign targeted university students in several European capitals, which yielded nearly 40% new customers for T-Craze in one quarter. Right Target also ran subsequent campaigns for T- Craze, though with much less success.
The last two campaigns included a wider demographic group and resulted in countless unsubscribe requests, including a large number in Spain. In fact, the Spanish data protection authority received a complaint from Sofia, a mid-career investment banker. Sofia was upset after receiving a marketing communication even after unsubscribing from such communications from the Right Target on behalf of T-Craze.
Which of the following is T-Craze's lead supervisory authority?
- A. France, because that is where T-Craze conducts processing of personal information.
- B. Spain, because that is T-Craze's primary market based on its marketing campaigns.
- C. Germany, because that is where T-Craze is headquartered.
- D. T-Craze may choose its lead supervisory authority where any of its affiliates are based, because it has presence in several European countries.
Answer: B
NEW QUESTION 41
A mobile device application that uses cookies will be subject to the consent requirement of which of the following?
- A. The Data Retention Directive
- B. The E-Commerce Directive
- C. The EU Cybersecurity Directive
- D. The ePrivacy Directive
Answer: D
Explanation:
Explanation/Reference: https://www.iubenda.com/en/help/5525-cookies-gdpr-requirements
NEW QUESTION 42
Based on GDPR Article 35, which of the following situations would trigger the need to complete a DPIA?
- A. A company wants to combine location data with other data in order to offer more personalized service for the customer.
- B. A company wants to build a dating app that creates candidate profiles based on location data and data from third-party sources.
- C. A company wants to use location data to infer information on a person's clothes purchasing habits.
- D. A company wants to use location data to track delivery trucks in order to make the routes more efficient.
Answer: B
NEW QUESTION 43
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 dat a. 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?
- A. Any marketing information at all.
- B. No marketing information at all.
- C. Marketing information for products or services similar to those purchased from WonderKids.
- D. Marketing information related to other business operations of WonderKids.
Answer: D
NEW QUESTION 44
SCENARIO
Please use the following to answer the next question:
Javier is a member of the fitness club EVERFIT. This company has branches in many EU member states, but for the purposes of the GDPR maintains its primary establishment in France. Javier lives in Newry, Northern Ireland (part of the U.K.), and commutes across the border to work in Dundalk, Ireland. Two years ago while on a business trip, Javier was photographed while working out at a branch of EVERFIT in Frankfurt, Germany. At the time, Javier gave his consent to being included in the photograph, since he was told that it would be used for promotional purposes only. Since then, the photograph has been used in the club's U.K. brochures, and it features in the landing page of its U.K. website. However, the fitness club has recently fallen into disrepute due to widespread mistreatment of members at various branches of the club in several EU member states. As a result, Javier no longer feels comfortable with his photograph being publicly associated with the fitness club.
After numerous failed attempts to book an appointment with the manager of the local branch to discuss this matter, Javier sends a letter to EVETFIT requesting that his image be removed from the website and all promotional materials. Months pass and Javier, having received no acknowledgment of his request, becomes very anxious about this matter. After repeatedly failing to contact EVETFIT through alternate channels, he decides to take action against the company.
Javier contacts the U.K. Information Commissioner's Office ('ICO' - the U.K.'s supervisory authority) to lodge a complaint about this matter. The ICO, pursuant to Article 56 (3) of the GDPR, informs the CNIL (i.e. the supervisory authority of EVERFIT's main establishment) about this matter. Despite the fact that EVERFIT has an establishment in the U.K., the CNIL decides to handle the case in accordance with Article 60 of the GDPR.
The CNIL liaises with the ICO, as relevant under the cooperation procedure. In light of issues amongst the supervisory authorities to reach a decision, the European Data Protection Board becomes involved and, pursuant to the consistency mechanism, issues a binding decision.
Additionally, Javier sues EVERFIT for the damages caused as a result of its failure to honor his request to have his photograph removed from the brochure and website.
Assuming that multiple EVETFIT branches across several EU countries are acting as separate data controllers, and that each of those branches were responsible for mishandling Javier's request, how may Javier proceed in order to seek compensation?
- A. He will have to sue the EVETFIT's head office in France, where EVETFIT has its main establishment.
- B. He will be able to sue any one of the relevant EVETFIT branches, as each one may be held liable for the entire damage.
- C. He will have to sue each EVETFIT branch so that each branch provides proportionate compensation commensurate with its contribution to the damage or distress suffered by Javier.
- D. He will be able to apply to the European Data Protection Board in order to determine which particular EVETFIT branch is liable for damages, based on the decision that was made by the board.
Answer: A
NEW QUESTION 45
SCENARIO
Please use the following to answer the next question:
Anna and Frank both work at Granchester University. Anna is a lawyer responsible for data protection, while Frank is a lecturer in the engineering department. The University maintains a number of types of records:
* Student records, including names, student numbers, home addresses, pre-university information, university attendance and performance records, details of special educational needs and financial information.
* Staff records, including autobiographical materials (such as curricula, professional contact files, student evaluations and other relevant teaching files).
* Alumni records, including birthplaces, years of birth, dates of matriculation and conferrals of degrees.
These records are available to former students after registering through Granchester's Alumni portal.
* Department for Education records, showing how certain demographic groups (such as first-generation students) could be expected, on average, to progress. These records do not contain names or identification numbers.
* Under their security policy, the University encrypts all of its personal data records in transit and at rest.
In order to improve his teaching, Frank wants to investigate how his engineering students perform in relational to Department for Education expectations. He has attended one of Anna's data protection training courses and knows that he should use no more personal data than necessary to accomplish his goal. He creates a program that will only export some student data: previous schools attended, grades originally obtained, grades currently obtained and first time university attended. He wants to keep the records at the individual student level.
Mindful of Anna's training, Frank runs the student numbers through an algorithm to transform them into different reference numbers. He uses the same algorithm on each occasion so that he can update each record over time.
One of Anna's tasks is to complete the record of processing activities, as required by the GDPR. After receiving her email reminder, as required by the GDPR. After receiving her email reminder, Frank informs Anna about his performance database.
Ann explains to Frank that, as well as minimizing personal data, the University has to check that this new use of existing data is permissible. She also suspects that, under the GDPR, a risk analysis may have to be carried out before the data processing can take place. Anna arranges to discuss this further with Frank after she has done some additional research.
Frank wants to be able to work on his analysis in his spare time, so he transfers it to his home laptop (which is not encrypted). Unfortunately, when Frank takes the laptop into the University he loses it on the train. Frank has to see Anna that day to discuss compatible processing. He knows that he needs to report security incidents, so he decides to tell Anna about his lost laptop at the same time.
Which of the University's records does Anna NOT have to include in her record of processing activities?
- A. Student records
- B. Staff and alumni records
- C. Department for Education records
- D. Frank's performance database
Answer: B
NEW QUESTION 46
What is a reason the European Court of Justice declared the Data Retention Directive invalid in 2014?
- A. The requirements affected individuals without exception.
- B. The requirements had limitations on how national authorities could use data.
- C. The requirements specified that data must be held within the EU.
- D. The requirements were financially burdensome to EU businesses.
Answer: B
Explanation:
Reference:
%20the%20Grand,proportionality%20in%20forging%20the%20Directive.
NEW QUESTION 47
Which of the following is NOT an explicit right granted to data subjects under the GDPR?
- A. The right to request the deletion of data a controller holds about them.
- B. The right to request access to the personal data a controller holds about them.
- C. The right to request restriction of processing of personal data, under certain scenarios.
- D. The right to opt-out of the sale of their personal data to third parties.
Answer: B
NEW QUESTION 48
In addition to the European Commission, who can adopt standard contractual clauses, assuming that all required conditions are met?
- A. The Council of the European Union.
- B. National data protection authorities.
- C. The European Data Protection Supervisor.
- D. Approved data controllers.
Answer: D
Explanation:
Explanation/Reference: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/ standard-contractual-clauses-scc_en
NEW QUESTION 49
Under the GDPR, which essential pieces of information must be provided to data subjects before collecting their personal data?
- A. The identity and contact details of the controller and the reasons the data is being collected.
- B. The name/s of relevant government agencies involved and the steps needed for revising the data.
- C. The contact information of the controller and a description of the retention policy.
- D. The authority by which the controller is collecting the data and the third parties to whom the data will be sent.
Answer: A
Explanation:
Explanation/Reference: https://gdpr-info.eu/art-13-gdpr/
NEW QUESTION 50
In the event of a data breach, which type of information are data controllers NOT required to provide to either the supervisory authorities or the data subjects?
- A. The predicted consequences of the breach.
- B. The contact details of the appropriate data protection officer.
- C. The measures being taken to address the breach.
- D. The type of security safeguards used to protect the data.
Answer: B
NEW QUESTION 51
If a multi-national company wanted to conduct background checks on all current and potential employees, including those based in Europe, what key provision would the company have to follow?
- A. Background checks on European employees will stem from data protection and employment law, which can vary between member states.
- B. Background checks on employees could be performed only under prior notice to all employees.
- C. Background checks are only authorized with prior notice and express consent from all employees including those based in Europe.
- D. Background checks may not be allowed on European employees, but the company can create lists based on its legitimate interests, identifying individuals who are ineligible for employment.
Answer: A
NEW QUESTION 52
SCENARIO
Please use the following to answer the next question:
Ben is a member of the fitness club STAYFIT. This company has branches in many EU member states, but for the purposes of the GDPR maintains its primary establishment in France. Ben lives in Newry, Northern Ireland (part of the U.K.), and commutes across the border to work in Dundalk, Ireland. Two years ago while on a business trip, Ben was photographed while working out at a branch of STAYFIT in Frankfurt, Germany. At the time, Ben gave his consent to being included in the photograph, since he was told that it would be used for promotional purposes only. Since then, the photograph has been used in the club's U.K. brochures, and it features in the landing page of its U.K. website. However, the fitness club has recently fallen into disrepute due to widespread mistreatment of members at various branches of the club in several EU member states. As a result, Ben no longer feels comfortable with his photograph being publicly associated with the fitness club.
After numerous failed attempts to book an appointment with the manager of the local branch to discuss this matter, Ben sends a letter to STAYFIT requesting that his image be removed from the website and all promotional materials. Months pass and Ben, having received no acknowledgment of his request, becomes very anxious about this matter. After repeatedly failing to contact STAYFIT through alternate channels, he decides to take action against the company.
Ben contacts the U.K. Information Commissioner's Office ('ICO' - the U.K.'s supervisory authority) to lodge a complaint about this matter.
Under the cooperation mechanism, what should the lead authority (the CNIL) do after it has formed its view on the matter?
- A. Request that members of the seconding supervisory authority and the host supervisory authority co-draft a decision.
- B. Submit a draft decision to other supervisory authorities for their opinion.
- C. Submit a draft decision directly to the Commission to ensure the effectiveness of the consistency mechanism.
- D. Request that the other supervisory authorities provide the lead authority with a draft decision for its consideration.
Answer: D
NEW QUESTION 53
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 questionnaires, 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 questionnaires 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?
- A. The destruction of the stolen data makes any risk to the affected data subjects unlikely.
- B. The resulting obligation to notify data subjects would involve disproportionate effort.
- C. The incident resulted from the actions of a third-party that were beyond their control.
- D. The sensitivity of the categories of data involved in the incident was not substantial enough.
Answer: C
NEW QUESTION 54
A company in France suffers a robbery over the weekend owing to a faulty alarm system. When it is determined that the break-in involves the loss of a substantial amount of data, the company decides on a CCTV system to monitor for future incidents. Company technicians install cameras in the entrance of the building, hallways and offices. Footage is recorded continuously, and is monitored by the home office in the United States. What is the most realistic step the company could take to address their security concerns and comply with the personal data processing principles set out in Article 5 of the GDPR?
- A. Seek informed consent from company employees.
- B. Have cameras recording during work hours only.
- C. Restrict camera placement to building entrances only.
- D. Retain captured footage for no more than 30 days.
Answer: A
NEW QUESTION 55
- 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. Their decision to operate without a data protection officer.
- C. Their omission of data protection provisions in their contract with Company C.
- D. Their failure to provide sufficient security safeguards to Company A's data.
- E. 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.
Under the GDPR, which of Company B's actions would NOT be likely to trigger a potential enforcement action? - F. Their engagement of Company C to improve their payroll service.
Answer: F
NEW QUESTION 56
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