IAPP CIPP-E Exam Questions

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

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?

Please use the following to answer the next question:
TripBliss Inc. is a travel service company which has lost substantial revenue over the last
few years. Their new manager, Oliver, suspects that this is partly due to the company’s
outdated website. After doing some research, he meets with a sales representative from
the up-and-coming IT company Techiva, hoping that they can design a new, cutting-edge
website for TripBliss Inc.’s foundering business.
During negotiations, a Techiva representative describes a plan for gathering more
customer information through detailed Questionaires, which could be used to tailor their
preferences to specific travel destinations. TripBliss Inc. can choose any number of data
categories – age, income, ethnicity – that would help them best accomplish their goals.
Oliver loves this idea, but would also like to have some way of gauging how successful this
approach is, especially since the Questionaires will require customers to provide explicit
consent to having their data collected. The Techiva representative suggests that they also
run a program to analyze the new website’s traffic, in order to get a better understanding of
how customers are using it. He explains his plan
to place a number of cookies on customer devices. The cookies will allow the company to
collect IP addresses and other information, such as the sites from which the customers
came, how much time they spend on the TripBliss Inc. website, and which pages on the
site they visit. All of this information will be compiled in log files, which Techiva will analyze
by means of a special program. TripBliss Inc. would receive aggregate statistics to help
them evaluate the website’s effectiveness. Oliver enthusiastically engages Techiva for
these services.
Techiva assigns the analytics portion of the project to longtime account manager Leon
Santos. As is standard practice, Leon is given administrator rights to TripBliss Inc.’s
website, and can authorize access to the log files gathered from it. Unfortunately forTripBliss Inc., however, Leon is taking on this new project at a time when his dissatisfaction
with Techiva is at a high point. In order to take revenge for what he feels has been unfair
treatment at the hands of the company, Leon asks his friend Fred, a hobby hacker, for
help. Together they come up with the following plan: Fred will hack into Techiva’s system
and copy their log files onto a USB stick. Despite his initial intention to send the USB to the
press and to the data protection authority in order to denounce Techiva, Leon experiences
a crisis of conscience and ends up reconsidering his plan. He decides instead to securely
wipe all the data from the USB stick and inform his manager that the company’s system of
access control must be reconsidered.
With regard to TripBliss Inc.’s use of website cookies, which of the following statements is
correct?

Which sentence best describes proper compliance for an international organization using Binding Corporate Rules (BCRs) as a controller or processor?

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, preuniversity
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 improve 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.
Anna will find that a risk analysis is NOT necessary in this situation as long as?