IAPP CIPP-E - Questions & Answers

Read the following steps:

Discover which employees are accessing cloud services and from which devices and apps Lock down the data in those apps and devices Monitor and analyze the apps and devices for compliance Manage application life cycles Monitor data sharing An organization should perform these steps to do which of the following?

What is a reason the European Court of Justice declared the Data Retention Directive invalid in 2014?

Which of the following countries will continue to enjoy adequacy status under the GDPR, pending any future European Commission decision to the contrary?

Which of the following describes a mandatory requirement for a group of undertakings that wants to appoint a single data protection officer?

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 US., 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 levelreview, as it will save the company a lot of money that would otherwise be paid to its outside law firm.
Ben's collection of additional data from customers created several potential issues for the company, which would most likely require what?

A U.S.-based online shop uses sophisticated software to track the browsing behavior of its European customers and predict future purchases. It also shares this information with third parties.
Under the GDPR, what is the online shop's PRIMARY obligation while engaging in this kind of profiling?

SCENARIO

Please use the following to answer the next question:

Dynaroux Fashion (`Dynaroux') is a successful international online clothing retailer that employs
approximately 650 people at its headquarters based in Dublin, Ireland. Ronan is their recently appointed data protection officer, who oversees the company's compliance with the General Data Protection Regulation (GDPR) and other privacy legislation.

The company offers both male and female clothing lines across all age demographics, including children.
In doing so, the company processes large amounts of information about such customers, including preferences and sensitive financial information such as credit card and bank account numbers.

In an aggressive bid to build revenue growth, Jonas, the CEO, tells Ronan that the company is launching a new mobile app and loyalty scheme that puts significant emphasis on profiling the company's customers by analyzing their purchases. Ronan tells the CEO that: (a) the potential risks of such activities means that

Dynaroux needs to carry out a data protection impact assessment to assess this new venture and its
privacy implications; and (b) where the results of this assessment indicate a high risk in the absence of
appropriate protection measures, Dynaroux mayhave to undertake a prior consultation with the Irish Data Protection Commissioner before implementing the app and loyalty scheme.

Jonas tells Ronan that he is not happy about the prospect of having to directly engage with a supervisory authority and having to disclose details of Dynaroux's business plan and associated processing activities.

Which of the following facts about Dynaroux would trigger a data protection impact assessment under the GDPR?

Which GDPR requirement will present the most significant challenges for organizations with Bring Your Own Device (BYOD) programs?

What are the obligations of a processor that engages a sub-processor?

What type of data lies beyond the scope of the General Data Protection Regulation?