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 23, 2026

IAPP CIPP-E Online Questions & Answers

  • Question 281:

    SCENARIO

    Please use the following to answer the next question:

    Louis, a long-time customer of Bedrock Insurance, was involved in a minor car accident a few months ago. Although no one was hurt, Louis has been plagued by texts and calls from a company called Accidentable offering to help him recover

    compensation for personal injury. Louis has heard about insurance companies selling customers' data to third parties, and he's convinced that Accidentable must have gotten his information from Bedrock Insurance.

    Louis has also been receiving an increased amount of marketing information from Bedrock, trying to sell him their full range of their insurance policies.

    Perturbed by this, Louis has started looking at price comparison sites on the internet and has been shocked to find that other insurers offer much cheaper rates than Bedrock, even though he has been a loyal customer for many years. When

    his Bedrock policy comes up for renewal, he decides to switch to Zantrum Insurance.

    In order to activate his new insurance policy, Louis needs to supply Zantrum with information about his No Claims bonus, his vehicle and his driving history. After researching his rights under the GDPR, he writes to ask Bedrock to transfer his

    information directly to Zantrum. He also takes this opportunity to ask Bedrock to stop using his personal data for marketing purposes.

    Bedrock supplies Louis with a PDF and XML (Extensible Markup Language) versions of his No Claims Certificate, but tells Louis it cannot transfer his data directly to Zantrum as this is not technically feasible. Bedrock also explains that

    Louis's contract included a provision whereby Louis agreed that his data could be used for marketing purposes; according to Bedrock, it is too late for Louis to change his mind about this. It angers Louis when he recalls the wording of the

    contract, which was filled with legal jargon and very confusing.

    In the meantime, Louis is still receiving unwanted calls from Accidentable Insurance. He writes to Accidentable to ask for the name of the organization that supplied his details to them. He warns Accidentable 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.

    Accidentable's response letter confirms Louis's suspicions. Accidentable is Bedrock Insurance's wholly owned subsidiary, and they received information about Louis's accident from Bedrock shortly after Louis submitted his accident claim.

    Accidentable assures Louis that there has been no breach of the GDPR, as Louis's contract included, a provision in which he agreed to share his information with Bedrock's affiliates for business purposes.

    Louis is disgusted by the way in which he has been treated by Bedrock, and writes to them insisting that all his information be erased from their computer system.

    Which statement accurately summarizes Bedrock's obligation in regard to Louis's data portability request?

    A. Bedrock does not have a duty to transfer Louis's data to Zantrum if doing so is legitimately not technically feasible.
    B. Bedrock does not have to transfer Louis's data to Zantrum because the right to data portability does not apply where personal data are processed in order to carry out tasks in the public interest.
    C. Bedrock has failed to comply with the duty to transfer Louis's data to Zantrum because the duty applies wherever personal data are processed by automated means and necessary for the performance of a contract with the customer.
    D. Bedrock has failed to comply with the duty to transfer Louis's data to Zantrum 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.

  • Question 282:

    An organization conducts body temperature checks as a part of COVID-19 monitoring. Body temperature is measured manually and is not followed by registration, documentation or other processing of an individual's personal data. Which of the following best explain why this practice would NOT be subject to the GDPR?

    A. Body temperature is not considered personal data.
    B. The practice does not involve completion by automated means.
    C. Body temperature is considered pseudonymous data.
    D. The practice is for the purpose of alleviating extreme risks to public health.

  • Question 283:

    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.

  • Question 284:

    SCENARIO

    Please use the following to answer the next question:

    Jane starts her new role as a Data Protection Officer (DPO) at a Malta-based company that allows anyone to buy and sell cryptocurrencies via its online platform. The company stores and processes the personal data of its customers in a

    dedicated data center located in Malta (EU).

    People wishing to trade cryptocurrencies are required to open an online account on the platform. They then must successfully pass a Know Your Customer (KYC) due diligence procedure aimed at preventing money laundering and ensuring

    compliance with applicable financial regulations.

    The non-European customers are also required to waive all their GDPR rights by reading a disclaimer written in bold and ticking a checkbox on a separate page in order to get their account approved on the platform.

    All customers must likewise accept the terms of service of the platform. The terms of service also include a privacy policy section, saying, among other things, that if a customer fails the KYC process, its KYC data will be automatically shared

    with the national anti-money laundering agency.

    The KYC procedure requires customers to answer many questions, including whether they have any criminal convictions, whether they use recreational drugs or have problems with alcohol, and whether they have a terminal illness. While

    providing this data, customers see a conspicuous message saying that this data is meant only to prevent fraud and account takeover, and will be never shared with private third parties.

    The company regularly conducts external security testing of its online systems by independent cybersecurity companies from the EU. At the final stage of testing, the company provides cybersecurity assessors with access to its central

    database to review security permissions, roles and policies. Personal data in the database is encrypted; however, cybersecurity assessors usually have access to the decryption keys obtained while running initial security testing. The

    assessors must strictly follow the guidelines imposed by the company during the entire testing and auditing process.

    All customer data, including trading activities and all internal communications with technical support, are permanently stored in a secured AWS S3 Glacier cloud data storage, located in Ireland, for backup and compliance purposes. The data

    is securely transferred to the cloud and then is properly encrypted while at rest by using AWS-native encryption mechanisms. These mechanisms give AWS the necessary technical means to encrypt and decrypt the data when such is

    required by the company. There is no data processing agreement between AWS and the company.

    What is potentially wrong with the backup system operated in the AWS cloud?

    A. The AWS servers are located in the EU but in a country different than the location of the corporate headquarters.
    B. It is unlawful to process any personal data in a cloud unless the cloud is certified as GOPR-compliant by a competent supervisory authority.
    C. The data storage period has to be revised, and a data processing agreement w*h AWS must be signed
    D. AWS is a U S company, and no personal data of European residents may be transferred to it without explicit written consent from data subjects.

  • Question 285:

    A German data subject was the victim of an embarrassing prank 20 years ago. A newspaper website published an article about the prank at the time, and the article is still available on the newspaper's website. Unfortunately, the prank is the top search result when a user searches on the victim's name. The data subject requests that SearchCo delist this result. SearchCo agrees, and instructs its technology team to avoid scanning or indexing the article. What else must SearchCo do?

    A. Notify the newspaper that its article it is delisting the article.
    B. Fully erase the URL to the content, as opposed to delist which is mainly based on data subject's name.
    C. Identify other controllers who are processing the same information and inform them of the delisting request.
    D. Prevent the article from being listed in search results no matter what search terms are entered into the search engine.

  • Question 286:

    If a company chooses to ground an international data transfer on the contractual route, which of the following is NOT a valid set of standard contractual clauses?

    A. Decision 2001/497/EC (EU controller to non-EU or EEA controller).
    B. Decision 2004/915/EC (EU controller to non-EU or EEA controller).
    C. Decision 2007/72/EC (EU processor to non-EU or EEA controller).
    D. Decision 2010/87/EU (Non-EU or EEA processor from EU controller).

  • Question 287:

    What is the key difference between the European Council and the Council of the European Union?

    A. The Council of the European Union is helmed by a president.
    B. The Council of the European Union has a degree of legislative power.
    C. The European Council focuses primarily on issues involving human rights.
    D. The European Council is comprised of the heads of each EU member state.

  • Question 288:

    SCENARIO Please use the following to answer the next question:

    Gentle Hedgehog Inc. is a privately owned website design agency incorporated in Italy. The company has numerous remote workers in different EU countries. Recently, the management of Gentle Hedgehog noticed a decrease in productivity

    of their sales team, especially among remote workers. As a result, the company plans to implement a robust but privacy-friendly remote surveillance system to prevent absenteeism, reward top performers, and ensure the best quality of

    customer service when sales people are interacting with customers.

    Gentle Hedgehog eventually hires Sauron Eye Inc., a Chinese vendor of employee surveillance software whose European headquarters is in Germany. Sauron Eye s software provides powerful remote-monitoring capabilities, including 24/7

    access to computer cameras and microphones, screen captures, emails, website history, and keystrokes. Any device can be remotely monitored from a central server that is securely installed at Gentle Hedgehog headquarters. The

    monitoring is invisible by default; however, a so-called Transparent Mode, which regularly and conspicuously notifies all users about the monitoring and its precise scope, also exists. Additionally, the monitored employees are required to use

    a built-in verification technology involving facial recognition each time they log in.

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

    What is the main problem with the 24/7 camera monitoring?

    A. It must not be operated during non-business hours and employee holidays.
    B. It may accidentally film third parties whose consent is required for monitoring.
    C. It has no valid legal basis to be implemented in the context of Gentle Hedgehog’s business.
    D. It must first be approved by the trade union and then granted a license from the national DPA.

  • Question 289:

    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.

    What would be the MOST APPROPRIATE way for Building Block to handle the situation with the employee from Italy?

    A. Since the GDPR does not apply to this situation, the company would be entitled to apply any disciplinary measure authorized under Italian labor law.
    B. Since the employee was the cause of a serious risk for the server performance and their data, the company would be entitled to apply disciplinary measures to this employee, including fair dismissal.
    C. Since the employee was not informed that the security measures would be used for other purposes such as monitoring, the company could face difficulties in applying any disciplinary measures to this employee.
    D. Since this was a serious infringement, but the employee was not appropriately informed about the consequences the new security measures, the company would be entitled to apply some disciplinary measures, but not dismissal.

  • Question 290:

    Article 29 Working Party has emphasized that the GDPR forbids "forum shopping", which occurs when companies do what?

    A. Choose the data protection officer that is most sympathetic to their business concerns.
    B. Designate their main establishment in member state with the most flexible practices.
    C. File appeals of infringement judgments with more than one EU institution simultaneously.
    D. Select third-party processors on the basis of cost rather than quality of privacy protection.

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