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SCENARIO 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, pre-university 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?





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. Should Jane modify the required GDPR rights waiver for non-European residents?



Under Article 30 of the GDPR, controllers are required to keep records of all of the following EXCEPT?

A.

Incidents of personal data breaches, whether disclosed or not.

A.

Incidents of personal data breaches, whether disclosed or not.

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B.

Data inventory or data mapping exercises that have been conducted.

B.

Data inventory or data mapping exercises that have been conducted.

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C.

Categories of recipients to whom the personal data have been disclosed.

C.

Categories of recipients to whom the personal data have been disclosed.

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D.

Retention periods for erasure and deletion of categories of personal data.

D.

Retention periods for erasure and deletion of categories of personal data.

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Suggested answer: A

Explanation:

Article 30 of the GDPR requires controllers and processors to maintain records of their processing activities, which include information such as the purposes of the processing, the categories of personal data, the recipients of the data, the retention periods, and the security measures12. However, Article 30 does not require controllers to keep records of incidents of personal data breaches, whether disclosed or not.This is a separate obligation under Article 33 and Article 34, which require controllers to notify the supervisory authority and the data subjects of any personal data breach, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons34.Reference:1: Article 30 of the GDPR2: What do we need to document under Article 30 of the UK GDPR?| ICO3: Article 33 of the GDPR4: Article 34 of the GDPR

Section: (none)

Explanation:

In which scenario is a Controller most likely required to undertake a Data Protection Impact Assessment?

A.

When the controller is collecting email addresses from individuals via an online registration form for marketing purposes.

A.

When the controller is collecting email addresses from individuals via an online registration form for marketing purposes.

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B.

When personal data is being collected and combined with other personal data to profile the creditworthiness of individuals.

B.

When personal data is being collected and combined with other personal data to profile the creditworthiness of individuals.

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C.

When the controller is required to have a Data Protection Officer.

C.

When the controller is required to have a Data Protection Officer.

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D.

When personal data is being transferred outside of the EEA.

D.

When personal data is being transferred outside of the EEA.

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Suggested answer: B

Explanation:

According to the GDPR, a data protection impact assessment (DPIA) is a process to help identify and minimize the data protection risks of a project. A DPIA is required when the processing is likely to result in a high risk to the rights and freedoms of natural persons, taking into account the nature, scope, context and purposes of the processing. The GDPR provides a list of examples of processing operations that require a DPIA, such as:

Systematic and extensive evaluation of personal aspects relating to natural persons which is based on automated processing, including profiling, and on which decisions are based that produce legal effects concerning the natural person or similarly significantly affect the natural person.

Processing on a large scale of special categories of data or of personal data relating to criminal convictions and offences.

Systematic monitoring of a publicly accessible area on a large scale.

Therefore, an example of a scenario where a controller is most likely required to undertake a DPIA is when personal data is being collected and combined with other personal data to profile the creditworthiness of individuals, as this involves a systematic and extensive evaluation of personal aspects based on automated processing and profiling, and may have significant effects on the individuals. The other scenarios are not necessarily indicative of a high risk to the rights and freedoms of natural persons, and do not fall under the examples of processing operations that require a DPIA provided by the GDPR.Reference:Free CIPP/E Study Guide, page 37;CIPP/E Certification, page 18; GDPR, Article 35, Recital 91.

%20the%20General,and%20freedoms%20of%20natural%20persons%27.

Which of the following demonstrates compliance with the accountability principle found in Article 5, Section 2 of the GDPR?

A.

Anonymizing special categories of data.

A.

Anonymizing special categories of data.

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B.

Conducting regular audits of the data protection program.

B.

Conducting regular audits of the data protection program.

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C.

Getting consent from the data subject for a cross border data transfer.

C.

Getting consent from the data subject for a cross border data transfer.

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D.

Encrypting data in transit and at rest using strong encryption algorithms.

D.

Encrypting data in transit and at rest using strong encryption algorithms.

Answers
Suggested answer: B

Explanation:

The accountability principle found in Article 5, Section 2 of the GDPR requires data controllers to take responsibility for complying with the GDPR and to be able to demonstrate their compliance1.This means that data controllers must implement appropriate technical and organisational measures to ensure and show that they process personal data in accordance with the GDPR2. One of the measures that can demonstrate compliance with the accountability principle is conducting regular audits of the data protection program.Audits are systematic and independent assessments of the data processing activities and the data protection policies and procedures of an organisation3.They can help to identify and address any gaps or risks in the data protection program, as well as to verify the effectiveness and efficiency of the data protection measures3.Audits can also provide evidence of compliance to the supervisory authorities and the data subjects, as well as to enhance the trust and reputation of the organisation3.Therefore, conducting regular audits of the data protection program is a way to demonstrate compliance with the accountability principle.Reference:1: CIPP/E study guide, page 15;Art. 5 GDPR;Accountability principle | ICO2: CIPP/E study guide, page 16;Art. 24 GDPR; [Guide to accountability and governance | ICO]3: CIPP/E study guide, page 91; [Auditing | ICO]; [GDPR Audits: What You Need to Know - IT Governance Blog].

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 may have 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?

A.

The company will be undertaking processing activities involving sensitive data categories such as financial and children's data.

A.

The company will be undertaking processing activities involving sensitive data categories such as financial and children's data.

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B.

The company employs approximately 650 people and will therefore be carrying out extensive processing activities.

B.

The company employs approximately 650 people and will therefore be carrying out extensive processing activities.

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C.

The company plans to undertake profiling of its customers through analysis of their purchasing patterns.

C.

The company plans to undertake profiling of its customers through analysis of their purchasing patterns.

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D.

The company intends to shift their business model to rely more heavily on online shopping.

D.

The company intends to shift their business model to rely more heavily on online shopping.

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Suggested answer: C

Explanation:

According to theFree CIPP/E Study Guide, page 14, "the GDPR requires controllers to carry out a data protection impact assessment (DPIA) prior to processing where a type of processing, in particular using new technologies, and taking into account the nature, scope, context and purposes of the processing, is likely to result in a high risk to the rights and freedoms of natural persons." The GDPR also provides a list of examples of processing operations that require a DPIA, such as "a systematic and extensive evaluation of personal aspects relating to natural persons which is based on automated processing, including profiling, and on which decisions are based that produce legal effects concerning the natural person or similarly significantly affect the natural person" (Article 35(3)(a)). Therefore, the fact that Dynaroux plans to undertake profiling of its customers through analysis of their purchasing patterns would trigger a DPIA under the GDPR, as it involves a systematic and extensive evaluation of personal aspects based on automated processing that may significantly affect the customers. The other options are not necessarily cases where a DPIA is required, although they may involve other obligations under the GDPR, such as obtaining a valid legal basis, providing adequate safeguards, or informing the data subjects.Reference:

Free CIPP/E Study Guide, page 14

GDPR, Article 35

Which mechanism, new to the GDPR, now allows for the possibility of personal data transfers to third countries under Article 42?

A.

Approved certifications.

A.

Approved certifications.

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B.

Binding corporate rules.

B.

Binding corporate rules.

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C.

Law enforcement requests.

C.

Law enforcement requests.

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D.

Standard contractual clauses.

D.

Standard contractual clauses.

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Suggested answer: A

Explanation:

According to Article 42 of the GDPR, the Commission may approve certification mechanisms, seals and marks for the purpose of demonstrating the existence of appropriate safeguards for personal data transfers to third countries or international organisations. These certification mechanisms, seals and marks are voluntary and transparent, and are issued by accredited certification bodies or by the competent supervisory authorities. They are subject to the general provisions on certification in Articles 42 and 43 of the GDPR. They are intended to enhance the trust of data subjects and facilitate the free flow of personal data within the Union and beyond. They are also subject to periodic review and withdrawal or suspension if the conditions for certification are not or are no longer met.Reference:

Article 42 of the GDPR

European Data Protection Law & Practice textbook, Chapter 8: Transfers of Personal Data to Third Countries, Section 8.3: Appropriate Safeguards, Subsection 8.3.4: Certification Mechanisms, Seals and Marks

Guidelines 1/2018 on certification and identifying certification criteria in accordance with Articles 42 and 43 of the Regulation

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

A.

Employees must sign an ad hoc contractual agreement each time personal data is exported.

A.

Employees must sign an ad hoc contractual agreement each time personal data is exported.

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B.

All employees are subject to the rules in their entirety, regardless of where the work is taking place.

B.

All employees are subject to the rules in their entirety, regardless of where the work is taking place.

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C.

All employees must follow the privacy regulations of the jurisdictions where the current scope of their work is established.

C.

All employees must follow the privacy regulations of the jurisdictions where the current scope of their work is established.

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D.

Employees who control personal data must complete a rigorous certification procedure, as they are exempt from legal enforcement.

D.

Employees who control personal data must complete a rigorous certification procedure, as they are exempt from legal enforcement.

Answers
Suggested answer: B

Explanation:

According to Article 47(2)(a) of the GDPR, binding corporate rules (BCRs) must be legally binding and apply to and be enforced by every member concerned of the group of undertakings, or group of enterprises engaged in a joint economic activity, including their employees1. This means that all employees within the group must comply with the BCRs, irrespective of their location or the jurisdiction where they operate.The other options are incorrect, as they do not reflect the requirements of the GDPR or the guidance of the European Data Protection Board (EDPB) on BCRs23.Reference:

GDPR Article 47(2)(a)

EDPB Guidelines 3/2018 on the territorial scope of the GDPR

EDPB Guidelines 2/2018 on derogations of Article 49 under Regulation 2016/679

With respect to international transfers of personal data, the European Data Protection Board (EDPB) confirmed that derogations may be relied upon under what condition?

A.

If the data controller has received preapproval from a Data Protection Authority (DPA), after submitting the appropriate documents.

A.

If the data controller has received preapproval from a Data Protection Authority (DPA), after submitting the appropriate documents.

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B.

When it has been determined that adequate protection can be performed.

B.

When it has been determined that adequate protection can be performed.

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C.

Only if the Data Protection Impact Assessment (DPIA) shows low risk.

C.

Only if the Data Protection Impact Assessment (DPIA) shows low risk.

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D.

Only as a last resort and when interpreted restrictively.

D.

Only as a last resort and when interpreted restrictively.

Answers
Suggested answer: D

Explanation:

The GDPR allows for derogations for specific situations when a transfer of personal data to a third country or an international organization cannot be based on an adequacy decision, appropriate safeguards, or binding corporate rules1. However, these derogations are exceptions to the general rule and should not become the norm.The EDPB confirmed that derogations should only be used as a last resort and when interpreted restrictively, taking into account the nature of the data, the purpose and duration of the processing, the country of origin and destination, and the rights and freedoms of data subjects23.The EDPB also stressed that the data exporter must assess the level of protection in the third country and ensure that the transfer does not undermine the essence of the fundamental rights and freedoms of data subjects23.Reference:1: Article 49 of the GDPR2: Guidelines 2/2018 on derogations of Article 49 under Regulation 2016/6793: A guide to international transfers | ICO

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?

A.

Germany, because that is where T-Craze is headquartered.

A.

Germany, because that is where T-Craze is headquartered.

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B.

France, because that is where T-Craze conducts processing of personal information.

B.

France, because that is where T-Craze conducts processing of personal information.

Answers
C.

Spain, because that is T-Craze's primary market based on its marketing campaigns.

C.

Spain, because that is T-Craze's primary market based on its marketing campaigns.

Answers
D.

T-Craze may choose its lead supervisory authority where any of its affiliates are based, because it has presence in several European countries.

D.

T-Craze may choose its lead supervisory authority where any of its affiliates are based, because it has presence in several European countries.

Answers
Suggested answer: A

Explanation:

According to the GDPR, the lead supervisory authority is the supervisory authority with the primary responsibility for dealing with a cross-border processing activity, for example when a data subject makes a complaint about the processing of his or her personal data. The lead supervisory authority is determined according to the location of the main establishment or the single establishment of the controller or processor in the EU. The main establishment is the place where the decisions about the purposes and means of the processing are taken, or where the controller has its central administration in the EU. The single establishment is the only place where the controller or processor is established in the EU. Therefore, in this scenario, T-Craze's lead supervisory authority is Germany, because that is where T-Craze is headquartered and where it has its main product-design office, which implies that the decisions about the processing of personal data are taken there. The other options are not correct, because the location of the processing, the market or the affiliates are not relevant for determining the lead supervisory authority.Reference:Free CIPP/E Study Guide, page 39;CIPP/E Certification, page 19; GDPR, Article 4(16), Article 4(22), Article 56, Recital 36.

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.

Why does the Spanish supervisory authority notify the French supervisory authority when it opens an investigation into T-Craze based on Sofia's complaint?

A.

T-Craze has a French affiliate.

A.

T-Craze has a French affiliate.

Answers
B.

The French affiliate procured the services of Right Target.

B.

The French affiliate procured the services of Right Target.

Answers
C.

T-Craze conducts its marketing and sales activities in France.

C.

T-Craze conducts its marketing and sales activities in France.

Answers
D.

The Spanish supervisory authority is providing a courtesy notification not required under the GDPR.

D.

The Spanish supervisory authority is providing a courtesy notification not required under the GDPR.

Answers
Suggested answer: C

Explanation:

According to the CIPP/E study guide, Article 56 of the GDPR establishes the concept of the lead supervisory authority, which is the supervisory authority of the main or single establishment of the data controller or processor in the EU1.The lead supervisory authority has the primary responsibility for dealing with cross-border data processing, in cooperation with other concerned supervisory authorities1.Article 60 of the GDPR requires the lead supervisory authority to cooperate with the other supervisory authorities concerned in an endeavour to reach consensus2.The other supervisory authorities concerned are those that are established in a Member State where the data controller or processor has an establishment or where data subjects are substantially affected or likely to be substantially affected by the processing2. In the scenario, T-Craze is a German-headquartered company that has a French affiliate responsible for all marketing and sales activities. Therefore, the French supervisory authority is the lead supervisory authority for the processing of personal data related to the marketing and sales activities of T-Craze, as it is the supervisory authority of the main establishment of the data controller in the EU. The Spanish supervisory authority is a concerned supervisory authority, as it is the supervisory authority of the Member State where data subjects are likely to be substantially affected by the processing, such as Sofia who filed a complaint.Therefore, the Spanish supervisory authority notifies the French supervisory authority when it opens an investigation into T-Craze based on Sofia's complaint, in order to cooperate with the lead supervisory authority and seek consensus on the action to be taken2.Reference:1: CIPP/E study guide, page 87;Art. 56 GDPR;Guidelines 3/2018 on the territorial scope of the GDPR (Article 3)2: CIPP/E study guide, page 88;Art. 60 GDPR;Guidelines 3/2018 on the territorial scope of the GDPR (Article 3).

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

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.

What is the best option for the lead regulator when responding to the Spanish supervisory authority's notice that it plans to take action regarding Sofia's complaint?

A.

Accept, because it did not receive any complaints.

A.

Accept, because it did not receive any complaints.

Answers
B.

Accept, because GDPR permits non-lead authorities to take action for such complaints.

B.

Accept, because GDPR permits non-lead authorities to take action for such complaints.

Answers
C.

Reject, because Right Target's processing was conducted throughout Europe.

C.

Reject, because Right Target's processing was conducted throughout Europe.

Answers
D.

Reject, because GDPR does not allow other supervisory authorities to take action if there is a lead authority.

D.

Reject, because GDPR does not allow other supervisory authorities to take action if there is a lead authority.

Answers
Suggested answer: B

Explanation:

According to theFree CIPP/E Study Guide, page 16, "the GDPR provides for a one-stop-shop mechanism, which means that a controller or processor with establishments in several Member States will have only one supervisory authority as its interlocutor, which will act as the lead authority. However, this does not mean that the lead authority has exclusive competence to supervise all processing activities of the controller or processor throughout the EU. The GDPR also allows for the possibility of a relevant and reasoned objection by a concerned supervisory authority, which may trigger the consistency mechanism and the involvement of the European Data Protection Board (EDPB). Moreover, the GDPR recognizes the right of any supervisory authority to adopt urgent measures on its own territory or to commence legal proceedings before a court in its Member State in order to protect the rights and freedoms of data subjects." Therefore, the lead regulator should accept the Spanish supervisory authority's notice that it plans to take action regarding Sofia's complaint, as the GDPR permits non-lead authorities to take action for such complaints, especially when they involve urgent measures or legal proceedings to protect the data subjects' rights and freedoms. The other options are incorrect, as they do not reflect the GDPR's provisions on the one-stop-shop mechanism and the cooperation and consistency mechanisms.Reference:

Free CIPP/E Study Guide, page 16

GDPR, Articles 56, 60, 61, 62, 63, 64, 65 and 66

Total 271 questions
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