IAPP CIPP-E - Certified Information Privacy Professional/Europe (CIPP/E)
Article 58 of the GDPR describes the power of supervisory authorities. Which of the following is NOT among those granted?
A dynamic Internet Protocol (IP) address is considered persona! data when it is combined with what?
SCENARIO
Please use the following to answer the next question:
Financially, it has been a very good year at ARRA Hotels: Their 21 hotels, located in
Greece (5), Italy (15) and Spain (1), have registered their most profitable results
ever. To celebrate this achievement, ARRA Hotels' Human Resources office, based
in ARRA's main Italian establishment, has organized a team event for its 420
employees and their families at its hotel in Spain.
Upon arrival at the hotel, each employee and family member is given an electronic
wristband at the reception desk. The wristband serves a number of functions:
. Allows access to the "party zone" of the hotel, and emits a buzz if the user
approaches any unauthorized areas
. Allows up to three free drinks for each person of legal age, and emits a
buzz once this limit has been reached
. Grants a unique ID number for participating in the games and contests that
have been planned.
Along with the wristband, each guest receives a QR code that leads to the online
privacy notice describing the use of the wristband. The page also contains an
unchecked consent checkbox. In the case of employee family members under the
age of 16, consent must be given by a parent.
Among the various activities planned for the event, ARRA Hotels' HR office has
autonomously set up a photocall area, separate from the main event venue, where
employees can come and have their pictures taken in traditional carnival costume.
The photos will be posted on ARRA Hotels' main website for general marketing
purposes.
On the night of the event, an employee from one of ARRA's Greek hotels is
displeased with the results of the photos in which he appears. He intends to file a
complaint with the relevant supervisory authority in regard to the following:
. The lack of any privacy notice in the separate photocall area
The unlawful cross-border processing of his personal data
. The unacceptable aesthetic outcome of his photos
Assuming that there is a cross-border processing of personal data, which of the
following criteria would NOT be useful to the lead supervisory authority responsible
for the Greek employee's complaint when trying to determine the location of the
controller's main establishment?
SCENARIO
Please use the following to answer the next question:
ProStorage is a multinational cloud storage provider headquartered in the Netherlands. Its CEO. Ruth Brown, has developed a two-pronged strategy for growth: 1) expand ProStorage s global customer base and 2) increase ProStorage's sales force by efficiently onboarding effective teams. Enacting this strategy has recently been complicated by Ruth's health condition, which has limited her working hours, as well as her ability to travel to meet potential customers. ProStorage's Human Resources department and Ruth's Chief of Staff now work together to manage her schedule and ensure that she is able to make all her medical appointments The latter has become especially crucial after Ruth's last trip to India, where she suffered a medical emergency and was hospitalized m New Delhi Unable to reach Ruths family, the hospital reached out to ProStorage and was able to connect with her Chief of Staff, who in coordination with Mary, the head of HR. provided information to the doctors based on accommodate on requests Ruth made when she started a: ProStorage
In support of Ruth's strategic goals of hiring more sales representatives, the Human
Resources team is focused on improving its processes to ensure that new
employees are sourced, interviewed, hired, and onboarded efficiently. To help with
this, Mary identified two vendors, HRYourWay, a German based company, and
InstaHR, an Australian based company. She decided to have both vendors go
through ProStorage's vendor risk review process so she can work with Ruth to
make the final decision. As part of the review process, Jackie, who is responsible
for maintaining ProStorage's privacy program (including maintaining controller
BCRs and conducting vendor risk assessments), reviewed both vendors but
completed a transfer impact assessment only for InstaHR. After her review of both
vendors, she determined that InstaHR satisfied more of the requirements as it
boasted a more established privacy program and provided third-party attestations,
whereas HRYourWay was a small vendor with minimal data protection operations.
Thus, she recommended InstaHR.
ProStorage's marketing team also worked to meet the strategic goals of the
company by focusing on industries where it needed to grow its market share. To
help with this, the team selected as a partner UpFinance, a US based company
with deep connections to financial industry customers. During ProStorage's
diligence process, Jackie from the privacy team noted in the transfer impact
assessment that UpFinance implements several data protection measures
including end-to-end encryption, with encryption keys held by the customer.
Notably, UpFinance has not received any government requests in its 7 years of
business. Still, Jackie recommended that the contract require UpFinance to notify
ProStorage if it receives a government request for personal data UpFinance
processes on its behalf prior to disclosing such data.
What transfer mechanism should Jackie recommend for using InstaHR?
Which aspect of the GDPR will likely have the most impact on the consistent implementation of data protection
laws throughout the European Union?
Under the Data Protection Law Enforcement Directive of the EU, a government can carry out covert investigations involving personal data, as long it is set forth by law and constitutes a measure that is both necessary and what?
An entity’s website stores text files on EU users’ computer and mobile device browsers. Prior to doing so, the entity is required to provide users with notices containing information and consent under which of the following frameworks?
The GDPR forbids the practice of “forum shoppingâ€, which occurs when companies do what?
For which of the following operations would an employer most likely be justified in requesting the data subject’s consent?
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?
