Certified Information Privacy Professional/Europe (CIPP/E) Practice Test

IAPP-CIPP-E exam Format | Course Contents | Course Outline | exam Syllabus | exam Objectives

Exam Code: IAPP-CIPP-E
Exam Name: Certified Information Privacy Professional/Europe (CIPP/E)
Format: 90 multiple-choice questions (60 scored, 20 non-scored trial items).
Duration: 150 minutes (2.5 hours).
Passing Score: 300 out of 500 (approximately 65-80% correct answers).
Languages: Available in English, French, and German.

Domain I: Introduction to European Data Protection

- Origins and Historical Context of Data Protection Law:
- Evolution of data protection in Europe.
- Key milestones: European Convention on Human Rights (ECHR), Convention 108 (Council of Europe), OECD Privacy Guidelines.
- Influence of national data protection laws pre-GDPR.

- Human Rights Laws:
- Article 8 of the ECHR (right to privacy).
- Charter of Fundamental Rights of the European Union (Articles 7 and 8).
- Interaction between human rights and data protection.

- European Union Institutions:
- Roles of the European Commission, Council of the European Union, European Parliament, and Court of Justice of the European Union (CJEU).
- Influence of EU institutions on data protection policy.

- Legislative Framework:
- Overview of the GDPR and its scope.
- Pre-GDPR directives (e.g., Data Protection Directive 95/46/EC).
- Other relevant frameworks: ePrivacy Directive (2002/58/EC), Law Enforcement Directive (2016/680).

Domain II: European Data Protection Law and Regulation

- Data Protection Concepts:
- Personal data vs. non-personal data.
- Sensitive personal data (special categories under GDPR Article 9).
- Anonymization and pseudonymization.
- Data processing principles (lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality).

- Territorial and Material Scope of the GDPR:
- Application to EU and non-EU organizations (Article 3).
- Extraterritorial reach (e.g., targeting EU data subjects).
- Establishment and main establishment concepts.

- Data Processing Principles:
- GDPR Article 5 principles.
- Accountability and demonstrating compliance (Article 5(2)).

- Lawful Processing Criteria:
- Legal bases for processing (Article 6): consent, contract, legal obligation, vital interests, public task, legitimate interests.
- Conditions for consent (Article 7).
- Special categories of data (Article 9).

- Information Provision Obligations:
- Transparency requirements (Articles 12-14).
- Privacy notices and policies.
- Timing and format of information provision.

- Data Subjects’ Rights:
- Right to access (Article 15).
- Right to rectification (Article 16).
- Right to erasure (“right to be forgotten,” Article 17).
- Right to restriction of processing (Article 18).
- Right to data portability (Article 20).
- Right to object (Article 21).
- Automated decision-making and profiling (Article 22).

- Security of Personal Data:
- Technical and organizational measures (Article 32).
- Risk-based approach to security.
- Data breach notification requirements (Articles 33-34).

- Accountability Requirements:
- Data Protection by Design and by Default (Article 25).
- Data Protection Impact Assessments (DPIAs, Article 35).
- Record of processing activities (Article 30).
- Appointment of Data Protection Officers (DPOs, Articles 37-39).

Domain III: Compliance with European Data Protection Laws and Regulations

- International Data Transfers:
- GDPR Chapter V (Articles 44-50).
- Adequacy decisions (Article 45).
- Standard Contractual Clauses (SCCs).
- Binding Corporate Rules (BCRs).
- Schrems I and Schrems II rulings and their impact on EU-U.S. data transfers.
- Derogations (Article 49).

- Supervision and Enforcement:
- Role of Data Protection Authorities (DPAs).
- European Data Protection Board (EDPB) and European Data Protection Supervisor (EDPS).
- One-stop-shop mechanism (Article 56).
- Cooperation and consistency mechanisms (Articles 60-62).
- Fines and penalties (Article 83).

- Consequences for GDPR Violations:
- Administrative fines (up to €20 million or 4% of annual global turnover).
- Corrective measures (Article 58).
- Liability and compensation (Article 82).

- Employment Data:
- Processing employee data under GDPR.
- Workplace monitoring and consent.
- National variations in employment data protection.

- Direct Marketing:
- ePrivacy Directive and GDPR interplay.
- Consent for electronic marketing.
- Opt-in vs. opt-out rules.

- Internet Technology and Communications:
- Cookies and tracking technologies (ePrivacy Directive).
- Privacy by Design in technology.
- AI and data ethics.

- Financial and Health Data:
- Special considerations for financial data.
- Processing health data (Article 9(2)).
- National derogations for sensitive data.

- Personal Data: Any information relating to an identified or identifiable natural person (data subject).
- Data Subject: A natural person whose personal data is processed.
- Data Controller: The entity that determines the purposes and means of processing personal data.
- Data Processor: The entity that processes personal data on behalf of the controller.
- Processing: Any operation performed on personal data (e.g., collection, storage, use, deletion).
- GDPR: General Data Protection Regulation (EU) 2016/679, the primary EU data protection law.
- Consent: Freely given, specific, informed, and unambiguous agreement to data processing.
- Anonymization: Rendering personal data non-identifiable without the possibility of re-identification.
- Pseudonymization: Processing personal data so it can no longer be attributed to a data subject without additional information.
- Data Protection Officer (DPO): A designated individual responsible for overseeing GDPR compliance.
- Data Protection Authority (DPA): National or regional authority responsible for enforcing data protection laws.
- European Data Protection Board (EDPB): An EU body coordinating DPAs and issuing guidelines.
- Schrems II: A 2020 CJEU ruling invalidating the EU-U.S. Privacy Shield and emphasizing safeguards for international data transfers.
- Standard Contractual Clauses (SCCs): Pre-approved contractual terms for international data transfers.
- Binding Corporate Rules (BCRs): Internal policies for intra-group international data transfers.
- Data Protection Impact Assessment (DPIA): A process to identify and mitigate risks in high-risk data processing.
- Privacy by Design and by Default: Embedding data protection into systems and processes from the outset.
- ePrivacy Directive: EU Directive 2002/58/EC governing electronic communications and cookies.
- Adequacy Decision: An EU determination that a third country ensures an adequate level of data protection.
- One-Stop-Shop Mechanism: A GDPR process allowing organizations to deal primarily with one DPA for cross-border processing.

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Question: 121
Under which of the following conditions does the General Data Protection Regulation NOT apply to the processing of personal data?
1. When the personal data is processed only in non-electronic form
2. When the personal data is collected and then pseudonymised by the controller
3. When the personal data is held by the controller but not processed for further purposes
4. When the personal data is processed by an individual only for their household activities
Answer: D Explanation:
Reference: https://gdpr-info.eu/art-6-gdpr/
Question: 122
SCENARIO
Please use the following to answer the next question:
You have just been hired by a toy manufacturer based in Hong Kong. The company sells a broad range of dolls, action figures and plush toys that can be found internationally in a wide variety of retail stores. Although the manufacturer has no offices outside Hong Kong and in fact does not employ any staff outside Hong Kong, it has entered into a number of local distribution contracts. The toys produced by the company can be found in all popular toy stores throughout Europe, the United States and Asia. A large portion of the company�s revenue is due to international sales.
The company now wishes to launch a new range of connected toys, ones that can talk and interact with children. The CEO of the company is touting these toys as the next big thing, due to the increased possibilities offered: The figures can answer children�s questions on various subjects, such as mathematical calculations or the weather. Each figure is equipped with a microphone and speaker and can connect to any smartphone or tablet via Bluetooth. Any mobile device within a 10-meter radius can connect to the toys via Bluetooth as well. The figures can also be associated with other figures (from the same manufacturer) and interact with each other for an enhanced play experience.
When a child asks the toy a question, the request is sent to the cloud for analysis, and the answer is generated on cloud servers and sent back to the figure. The answer is given through the figure�s integrated speakers, making it appear as though that the toy is actually responding to the child�s question. The packaging of the toy does not provide technical details on how this works, nor does it mention that this feature requires an internet connection. The necessary data processing for this has been outsourced to a data center located in South Africa.
However, your company has not yet revised its consumer-facing privacy policy to indicate this.
In parallel, the company is planning to introduce a new range of game systems through which consumers can play the characters they acquire in the course of playing the game. The system will come bundled with a portal that includes a Near-Field Communications (NFC) reader. This device will read an RFID tag in the action figure, making the figure come to life onscreen. Each character has its own stock features and abilities, but it is also possible to earn additional ones by accomplishing game goals. The only information stored in the tag relates to the figures� abilities. It is easy to switch characters during the game, and it is possible to bring the figure to locations outside of the home and have the character�s abilities remain intact.
What presents the BIGGEST potential privacy issue with the company�s practices?
1. The NFC portal can read any data stored in the action figures
2. The information about the data processing involved has not been specified
3. The cloud service provider is in a country that has not been deemed adequate
4. The RFID tag in the action figures has the potential for misuse because of the toy�s evolving capabilities
Answer: B Question: 123 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 Excellerate 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.
Before Anna determines whether Frank�s performance database is permissible, what additional information does she need?
1. More information about Frank�s data protection training.
2. More information about the extent of the information loss.
3. More information about the algorithm Frank used to mask student numbers.
4. More information about what students have been told and how the research will be used.
Answer: D
Question: 124
Which aspect of the GDPR will likely have the most impact on the consistent implementation of data protection laws throughout the European Union?
1. That it essentially functions as a one-stop shop mechanism
2. That it takes the form of a Regulation as opposed to a Directive
3. That it makes notification of large-scale data breaches mandatory
4. That it makes appointment of a data protection officer mandatory
Answer: A Explanation:
Reference: https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en
Question: 125
SCENARIO
Please use the following to answer the next question:
You have just been hired by a toy manufacturer based in Hong Kong. The company sells a broad range of dolls, action figures and plush toys that can be found internationally in a wide variety of retail stores. Although the manufacturer has no offices outside Hong Kong and in fact does not employ any staff outside Hong Kong, it has entered into a number of local distribution contracts. The toys produced by the company can be found in all popular toy stores throughout Europe, the United States and Asia. A large portion of the company�s revenue is due to international sales.
The company now wishes to launch a new range of connected toys, ones that can talk and interact with children. The CEO of the company is touting these toys as the next big thing, due to the increased possibilities offered: The figures can answer children�s questions on various subjects, such as mathematical calculations or the weather. Each figure is equipped with a microphone and speaker and can connect to any smartphone or tablet via Bluetooth. Any mobile device within a 10-meter radius can connect to the toys via Bluetooth as well. The figures can also be associated with other figures (from the same manufacturer) and interact with each other for an enhanced play experience.
When a child asks the toy a question, the request is sent to the cloud for analysis, and the answer is generated on cloud servers and sent back to the figure. The answer is given through the figure�s integrated speakers, making it appear as though that the toy is actually responding to the child�s question. The packaging of the toy does not provide technical details on how this works, nor does it mention that this feature requires an internet connection. The necessary data processing for this has been outsourced to a data center located in South Africa.
However, your company has not yet revised its consumer-facing privacy policy to indicate this.
In parallel, the company is planning to introduce a new range of game systems through which consumers can play the characters they acquire in the course of playing the game. The system will come bundled with a portal that includes a Near-Field Communications (NFC) reader. This device will read an RFID tag in the action figure, making the figure come to life onscreen. Each character has its own stock features and abilities, but it is also possible to earn additional ones by accomplishing game goals. The only information stored in the tag relates to the figures� abilities. It is easy to switch characters during the game, and it is possible to bring the figure to locations outside of the home and have the character�s abilities remain intact.
In light of the requirements of Article 32 of the GDPR (related to the Security of Processing), which practice should the company institute?
1. Encrypt the data in transit over the wireless Bluetooth connection.
2. Include dual-factor authentication before each use by a child in order to ensure a minimum amount of security.
3. Include three-factor authentication before each use by a child in order to ensure the best level of security possible.
4. Insert contractual clauses into the contract between the toy manufacturer and the cloud service provider, since South Africa is outside the European Union.
Answer: A Question: 126 SCENARIO
Please use the following to answer the next question:
You have just been hired by a toy manufacturer based in Hong Kong. The company sells a broad range of dolls, action figures and plush toys that can be found internationally in a wide variety of retail stores. Although the manufacturer has no offices outside Hong Kong and in fact does not employ any staff outside Hong Kong, it has entered into a number of local distribution contracts. The toys produced by the company can be found in all popular toy stores throughout Europe, the United States and Asia. A large portion of the company�s revenue is due to international sales.
The company now wishes to launch a new range of connected toys, ones that can talk and interact with children. The CEO of the company is touting these toys as the next big thing, due to the increased possibilities offered: The figures can answer children�s questions on various subjects, such as mathematical calculations or the weather. Each figure is equipped with a microphone and speaker and can connect to any smartphone or tablet via Bluetooth. Any mobile device within a 10-meter radius can connect to the toys via Bluetooth as well. The figures can also be associated with other figures (from the same manufacturer) and interact with each other for an enhanced play experience.
When a child asks the toy a question, the request is sent to the cloud for analysis, and the answer is generated on cloud servers and sent back to the figure. The answer is given through the figure�s integrated speakers, making it appear as though that the toy is actually responding to the child�s question. The packaging of the toy does not provide technical details on how this works, nor does it mention that this feature requires an internet connection. The necessary data processing for this has been outsourced to a data center located in South Africa.
However, your company has not yet revised its consumer-facing privacy policy to indicate this.
In parallel, the company is planning to introduce a new range of game systems through which consumers can play the characters they acquire in the course of playing the game. The system will come bundled with a portal that includes a Near-Field Communications (NFC) reader. This device will read an RFID tag in the action figure, making the figure come to life onscreen. Each character has its own stock features and abilities, but it is also possible to earn additional ones by accomplishing game goals. The only information stored in the tag relates to the figures� abilities. It is easy to switch characters during the game, and it is possible to bring the figure to locations outside of the home and have the character�s abilities remain intact.
Why is this company obligated to comply with the GDPR?
A. The company has offices in the E
C. The company employs staff in the E
E. The company�s data center is located in a country outside the E
G. The company�s products are marketed directly to EU customers.
Answer: D
Question: 127
What is the consequence if a processor makes an independent decision regarding the purposes and means of processing it carries out on behalf of a controller?
1. The controller will be liable to pay an administrative fine
2. The processor will be liable to pay compensation to affected data subjects
3. The processor will be considered to be a controller in respect of the processing concerned
4. The controller will be required to demonstrate that the unauthorized processing negatively affected one or more of the parties involved
Answer: C Explanation:
Reference: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-dataprotection-regulation-gdpr/key-definitions/controllers-and-processors/
Question: 128
How is the retention of communications traffic data for law enforcement purposes addressed by European data protection law?
1. The ePrivacy Directive allows individual EU member states to engage in such data retention.
2. The ePrivacy Directive harmonizes EU member states� rules concerning such data retention.
3. The Data Retention Directive�s annulment makes such data retention now permissible.
4. The GDPR allows the retention of such data for the prevention, investigation, detection or prosecution of criminal offences only.
Answer: D Explanation:
Reference: https://www.law.kuleuven.be/citip/en/archive/copy_of_publications/440retention-of-traffic-datadumortier-goemans2f90.pdf (9)
Question: 129
According to the GDPR, how is pseudonymous personal data defined?
1. Data that can no longer be attributed to a specific data subject without the use of additional information kept separately.
2. Data that can no longer be attributed to a specific data subject, with no possibility of re-identifying the data.
3. Data that has been rendered anonymous in such a manner that the data subject is no longer identifiable.
4. Data that has been encrypted or is subject to other technical safeguards.
Answer: A Explanation:
Reference: https://www.chino.io/blog/what-is-pseudonymous-data-according-to-the-gdpr/
Question: 130
SCENARIO
Please use the following to answer the next question:
Jason, a long-time customer of ABC insurance, was involved in a minor car accident a few months ago. Although no one was hurt, Jason has been plagued by texts and calls from a company called Erbium Insurance offering to help him recover compensation for personal injury. Jason has heard about insurance companies selling customers� data to
third parties, and he�s convinced that Erbium must have gotten his information from ABC.
Jason has also been receiving an increased amount of marketing information from ABC, trying to sell him their full range of their insurance policies.
Perturbed by this, Jason has started looking at price comparison sites on the Internet and has been shocked to find that other insurers offer much cheaper rates than ABC, even though he has been a loyal customer for many years. When his ABC policy comes up for renewal, he decides to switch to Xentron Insurance.
In order to activate his new insurance policy, Jason needs to supply Xentron with information about his No Claims bonus, his vehicle and his driving history. After researching his rights under the GDPR, he writes to ask ABC to transfer his information directly to Xentron. He also takes this opportunity to ask ABC to stop using his personal data for marketing purposes.
ABC supplies Jason with a PDF and XML (Extensible Markup Language) versions of his No Claims Certificate, but tells Jason it cannot transfer his data directly to Xentron at this is not technically feasible. ABC also explains that Jason�s contract included a provision whereby Jason agreed that his data could be used for marketing purposes; according to ABC, it is too late for Jason to change his mind about this. It angers Jason when he recalls the wording of the contract, which was filled with legal jargon and very confusing.
In the meantime, Jason is still receiving unwanted calls from Erbium Insurance. He writes to Erbium to ask for the name of the organization that supplied his details to them. He warns Erbium that he plans to complain to the data protection authority because he thinks their company has been using his data unlawfully. His letter states that he does not want his data being used by them in any way.
Erbium�s response letter confirms Jason�s suspicions. Erbium is ABC�s wholly owned subsidiary, and they received information about Jason�s accident from ABC shortly after Jason submitted his accident claim. Erbium assures Jason that there has been no breach of the GDPR, as Jason�s contract included a provision in which he agreed to share his information with ABC�s affiliates for business purposes.
Jason is disgusted by the way in which he has been treated by ABC, and writes to them insisting that all his information be erased from their computer system. Which statement accurately summarizes ABC�s obligation in regard to Jason�s data portability request?
1. ABC does not have a duty to transfer Jason�s data to Xentron if doing so is legitimately not technically feasible.
2. ABC does not have to transfer Jason�s data to Xentron because the right to data portability does not apply where personal data are processed in order to carry out tasks in the public interest.
3. ABC has failed to comply with the duty to transfer Jason�s data to Xentron because the duty applies wherever personal data are processed by automated means and necessary for the performance of a contract with the customer.
4. ABC has failed to comply with the duty to transfer Jason�s data to Xentron because it has an obligation to develop commonly used, machine-readable and interoperable formats so that all customer data can be ported to other insurers on request.
Answer: C

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