CIPP-E Exam Details

  • Exam Code
    :CIPP-E
  • Exam Name
    :Certified Information Privacy Professional/Europe (CIPP/E)
  • Certification
    :IAPP Certifications
  • Vendor
    :IAPP
  • Total Questions
    :307 Q&As
  • Last Updated
    :May 31, 2026

IAPP CIPP-E Online Questions & Answers

  • Question 211:

    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 companycan 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?

    A. Encrypt the data in transit over the wireless Bluetooth connection.
    B. Include dual-factor authentication before each use by a child in order to ensure a minimum amount of security.
    C. Include three-factor authentication before each use by a child in order to ensure the best level of security possible.
    D. Insert contractual clauses into the contract between the toy manufacturer and the cloud service provider, since South Africa is outside the European Union.

  • Question 212:

    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:

    1.

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

    2.

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

    3.

    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:

    1.

    The lack of any privacy notice in the separate photocall area

    2.

    The unlawful cross-border processing of his personal data

    3.

    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.

  • Question 213:

    Since blockchain transactions are classified as pseudonymous, are they considered to be within the material scope of the GDPR or outside of it?

    A. Outside the material scope of the GDPR, because transactions do not include personal data about data subjects m the European Union.
    B. Within the material scope of the GDPR but outside of the territorial scope, because blockchains are decentralized.
    C. Within the material scope of the GDPR to the extent that transactions include data subjects in the European Union.
    D. Outside the material scope of the GDPR, because transactions are for personal or household purposes

  • Question 214:

    Under the GDPR, which of the following is true in regard to adequacy decisions involving cross-border transfers?

    A. The European Commission can adopt an adequacy decision for individual companies.
    B. The European Commission can adopt, repeal or amend an existing adequacy decision.
    C. EU member states are vested with the power to accept or reject a European Commission adequacy decision.
    D. To be considered as adequate, third countries must implement the EU General Data Protection Regulation into their national legislation.

  • Question 215:

    What obligation does a data controller or processor have after appointing a data protection officer?

    A. To ensure that the data protection officer receives sufficient instructions regarding the exercise of his or her defined tasks.
    B. To provide resources necessary to carry out the defined tasks of the data protection officer and to maintain his or her expert knowledge.
    C. To ensure that the data protection officer acts as the sole point of contact for individuals' Questions: about their personal data.
    D. To submit for approval to the data protection officer a code of conduct to govern organizational practices and demonstrate compliance with data protection principles.

  • Question 216:

    SCENARIO

    Please use the following to answer the next question:

    Joe is the new privacy manager for Who-R-U, a Canadian business that provides DNA analysis. The company is headquartered in Montreal, and all of its employees are located there. The company offers its services to Canadians only: Its website is in English and French, it accepts only Canadian currency, and it blocks internet traffic from outside of Canada (although this solution doesn't prevent all non-Canadian traffic). Italso declines to process orders that request the DNA report to be sent outside of Canada, and returns orders that show a non-Canadian return address.

    Bob, the President of Who-R-U, thinks there is a lot of interest for the product in the EU, and the company is exploring a number of plans to expand its customer base.

    The first plan, collegially called We-Track-U, will use an app to collect information about its current Canadian customer base. The expansion will allow its Canadian customers to use the app while traveling abroad. He suggests that the company use this app to gather location information. If the plan shows promise, Bob proposes to use push notifications and text messages to encourage existing customers to pre-register for an EU version of the service. Bob calls this work plan, We-Text-U. Once the company has gathered enough pre-registrations, it will develop EU-specific content and services.

    Another plan is called Customer for Life. The idea is to offer additional services through the company's app, like storage and sharing of DNA information with other applications and medical providers. The company's contract says that it can keep customer DNA indefinitely, and use it to offer new services and market them to customers. It also says that customers agree not to withdraw direct marketing consent. Paul, the marketing director, suggests that the company should fully exploit these provisions, and that it can work around customers' attempts to withdraw consent because the contract invalidates them.

    The final plan is to develop a brand presence in the EU. The company has already begun this process. It is in the process of purchasing the naming rights for a building in Germany, which would come with a few offices that Who-R-U executives can use while traveling internationally. The office doesn't include any technology or infrastructure; rather, it's simply a room with a desk and some chairs.

    On a recent trip concerning the naming-rights deal, Bob's laptop is stolen. The laptop held unencrypted DNA reports on 5,000 Who-R-U customers, all of whom are residents of Canada. The reports include customer name, birthdate, ethnicity, racial background, names of relatives, gender, and occasionally health information.

    The Customer for Life plan may conflict with which GDPR provision?

    A. Article 6, which requires processing to be lawful.
    B. Article 7, which requires consent to be as easy to withdraw as it is to give.
    C. Article 16, which provides data subjects with a rights to rectification.
    D. Article 20, which gives data subjects a right to data portability.

  • Question 217:

    A company has collected personal data tor direct marketing purpose on the basis of consent. It is now considering using this data to develop new products through analytics. What is the company first required to do?

    A. Obtain specific consent for the new processing
    B. Only inform the data subjects of the new purpose.
    C. Proceed no further, as such repurposing is unlawful
    D. Update the privacy notice upon which consent was given

  • Question 218:

    SCENARIO

    Please use the following to answer the next question:

    Joe is the new privacy manager for Who-R-U, a Canadian business that provides DNA analysis. The company is headquartered in Montreal, and all of its employees are located there. The company offers its services to Canadians only: Its

    website is in English and French, it accepts only Canadian currency, and it blocks internet traffic from outside of Canada (although this solution doesn't prevent all non-Canadian traffic). It also declines to process orders that request the DNA

    report to be sent outside of Canada, and returns orders that show a non-Canadian return address.

    Bob, the President of Who-R-U, thinks there is a lot of interest for the product in the EU, and the company is exploring a number of plans to expand its customer base.

    The first plan, collegially called We-Track-U, will use an app to collect information about its current Canadian customer base. The expansion will allow its Canadian customers to use the app while traveling abroad. He

    suggests that the company use this app to gather location information. If the plan shows promise, Bob proposes to use push notifications and text messages to encourage existing customers to pre-register for an EU version of the service.

    Bob calls this work plan, We-Text-U. Once the company has gathered enough pre-registrations, it will develop EU-specific content and services.

    Another plan is called Customer for Life. The idea is to offer additional services through the company's app, like storage and sharing of DNA information with other applications and medical providers. The company's contract says that it can

    keep customer DNA indefinitely, and use it to offer new services and market them to customers. It also says that customers agree not to withdraw direct marketing consent. Paul, the marketingdirector, suggests that the company should fully

    exploit these provisions, and that it can work around customers' attempts to withdraw consent because the contract invalidates them.

    The final plan is to develop a brand presence in the EU. The company has already begun this process. It is in the process of purchasing the naming rights for a building in Germany, which would come with a few offices that Who-R-U

    executives can use while traveling internationally. The office doesn't include any technology or infrastructure; rather, it's simply a room with a desk and some chairs.

    On a recent trip concerning the naming-rights deal, Bob's laptop is stolen. The laptop held unencrypted DNA reports on 5,000 Who-R-U customers, all of whom are residents of Canada. The reports include customer name, birthdate, ethnicity,

    racial background, names of relatives, gender, and occasionally health information.

    If Who-R-U adopts the We-Track-U pilot plan, why is it likely to be subject to the territorial scope of the GDPR?

    A. Its plan would be in the context of the establishment of a controller in the Union.
    B. It would be offering goods or services to data subjects in the Union.
    C. It is engaging in commercial activities conducted in the Union.
    D. It is monitoring the behavior of data subjects in the Union.

  • Question 219:

    Which statement is correct when considering the right to privacy under Article 8 of the European Convention on Human Rights (ECHR)?

    A. The right to privacy is an absolute right
    B. The right to privacy has to be balanced against other rights under the ECHR
    C. The right to freedom of expression under Article 10 of the ECHR will always override the right to privacy
    D. The right to privacy protects the right to hold opinions and to receive and impart ideas without interference

  • Question 220:

    SCENARIO

    Please use the following to answer the next question:

    Jack worked as a Pharmacovigiliance Operations Specialist in the Irish office of a multinational pharmaceutical company on a clinical trial related to COVID-19. As part of his onboarding process Jack received privacy training He was explicitly informed that while he would need to process confidential patient data in the course of his work, he may under no circumstances use this data for anything other than the performance of work-related (asks This was also specified in the privacy policy, which Jack signed upon conclusion of the training.

    After several months of employment, Jack got into an argument with a patient over the phone. Out of anger he later posted the patient's name and hearth information, along with disparaging comments, on a social media website. When this was discovered by his Pharmacovigilance supervisors. Jack was immediately dismissed

    Jack's lawyer sent a letter to the company stating that dismissal was a disproportionate sanction, and that if Jack was not reinstated within 14 days his firm would have no alternative but to commence legal proceedings against the company. This letter was accompanied by a data access request from Jack requesting a copy of "all personal data, including internal emails that were sent/received by Jack or where Jack is directly or indirectly identifiable from the contents In relation to the emails Jack listed six members of the management team whose inboxes he required access.

    The company conducted an initial search of its IT systems, which returned a large amount of information They then contacted Jack, requesting that he be more specific regarding what information he required, so that they could carry out a targeted search Jack responded by stating that he would not narrow the scope of the information requester.

    Under Article 82 of the GDPR ("Right to compensation and liability-), which party is liable for the damage caused by the data breach?

    A. Both parties are exempt, as the company is involved in human health research
    B. Jack and the pharmaceutical company are jointly liable.
    C. The pharmaceutical company is liable.
    D. Jack is liable

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