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IAPP CIPP-E Exam Dumps

IAPP CIPP-E Exam Dumps

Certified Information Privacy Professional/Europe (CIPP/E)

Total Questions : 307
Update Date : July 16, 2026
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CIPP-E Exam Dumps


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IAPP CIPP-E Sample Questions

Question # 1

Which of the following was the first to implement national law for data protection in 1973? 

A. France  
B. Sweden  
C. Germany  
D. United Kingdom  



Question # 2

SCENARIOPlease use the following to answer the next question:Jack worked as a Pharmacovigiliance Operations Specialist in the Irish office of amultinational pharmaceutical company on a clinical trial related to COVID-19. As part of hisonboarding process Jack received privacy training He was explicitly informed that while hewould need to process confidential patient data in the course of his work, he may under nocircumstances use this data for anything other than the performance of work-related (asksThis was also specified in the privacy policy, which Jack signed upon conclusion of thetraining.After several months of employment, Jack got into an argument with a patient over thephone. Out of anger he later posted the patient's name and hearth information, along withdisparaging comments, on a social media website. When this was discovered by hisPharmacovigilance supervisors. Jack was immediately dismissedJack's lawyer sent a letter to the company stating that dismissal was a disproportionatesanction, and that if Jack was not reinstated within 14 days his firm would have noalternative but to commence legal proceedings against the company. This letter wasaccompanied by a data access request from Jack requesting a copy of "all personal data,including internal emails that were sent/received by Jack or where Jack is directly orindirectly identifiable from the contents * In relation to the emails Jack listed six members ofthe management team whose inboxes he required access.The company conducted an initial search of its IT systems, which returned a large amountof information They then contacted Jack, requesting that he be more specific regardingwhat information he required, so that they could carry out a targeted search Jackresponded by stating that he would not narrow the scope of the information requester.What would be the most appropriate response to Jacks data subject access request?

A. The company should not provide any information, as the company is headquarteredoutside of the EU. 
B. The company should decline to provide any information, as the amount of informationrequested is too excessive to provide in one month. 
C. The company should cite the need for an extension, and agree to provide theinformation requested in Jack's original DSAR within a period of 3 months. 
D. The company should provide all requested information except for the emails, as they areexcluded from data access request requirements under the GDPR. 



Question # 3

The GDPR's list of processor obligations regarding cloud computing includes all of thefollowing EXCEPT?

A. Controllers must be given notice of any subprocessors and have a right of objection.  
B. Individuals authorized to process the personal data are subject to an obligation of confidentiality. 
C. Any personal data related to data subjects must be securely maintained for a maximumof ten years. 
D. Processors must implement technical and organizational measures to ensure a level ofsecurity appropriate to the risk. 



Question # 4

According to the European Data Protection Board, which of the following concepts orpractices does NOT follow from the principles relating to the processing of personal dataunder EU data protection law?

A. Data ownership allocation.  
B. Access control management.  
C. Frequent pseudonymization key rotation.  
D. Error propagation avoidance along the processing chain.  



Question # 5

What monitoring may lawfully be performed within the scope of Gentle Hedgehog'sbusiness?

A. Everything offered by Sauron Eye's software in relation to activity by sales team contractors. 
B. Everything offered by Sauron Eye's software, assuming employees provide dailyconsent to the monitoring. 
C. Only emails, website browsing history, and camera for internal video calls conducted ina non-secure environment. 
D. Only emails, website browsing history, and camera for internal video calls that areexpressly marked as monitored. 



Question # 6

ISO 31700 has set forth requirements relating to consumer products and services. Inparticular, this international standard focuses on the implementation of which of thefollowing?

A. Privacy by design.  
B. Comprehensive ethical Al software.  
C. Privacy notices for companies providing services to consumers.  
D. Automated systems for identifying EU data subjects' personal data.  



Question # 7

SCENARIOPlease use the following to answer the next question:Liem, an online retailer known for its environmentally friendly shoes, has recently expandedits presence in Europe. Anxious to achieve market dominance, Liem teamed up withanother eco friendly company, EcoMick, which sells accessories like belts and bags.Together the companies drew up a series of marketing campaigns designed to highlight theenvironmental and economic benefits of their products. After months of planning, Liem andEcoMick entered into a data sharing agreement to use the same marketing database,MarketIQ, to send the campaigns to their respective contacts.Liem and EcoMick also entered into a data processing agreement with MarketIQ, the termsof which included processing personal data only upon Liem and EcoMick’s instructions,and making available to them all information necessary to demonstrate compliance withGDPR obligations.Liem and EcoMick then procured the services of a company called JaphSoft, a marketingoptimization firm that uses machine learning to help companies run successful campaigns.Clients provide JaphSoft with the personal data of individuals they would like to be targetedin each campaign. To ensure protection of itsclients’ data, JaphSoft implements the technical and organizational measures it deemsappropriate. JaphSoft works to continually improve its machine learning models byanalyzing the data it receives from its clients to determine the most successful componentsof a successful campaign. JaphSoft then uses such models in providing services to itsclient-base. Since the models improve only over a period of time as more information iscollected, JaphSoft does not have a deletion process for the data it receives from clients.However, to ensure compliance with data privacy rules, JaphSoft pseudonymizes thepersonal data by removing identifyinginformation from the contact information. JaphSoft’s engineers, however, maintain allcontact information in the same database as the identifying information.Under its agreement with Liem and EcoMick, JaphSoft received access to MarketIQ, whichincluded contact information as well as prior purchase history for such contacts, to createcampaigns that would result in the most views of the two companies’ websites. A prior Liemcustomer, Ms. Iman, received a marketing campaign from JaphSoft regarding Liem’s aswell as EcoMick’s latest products. While Ms. Iman recalls checking a box to receiveinformation in the future regarding Liem’s products, she has never shopped EcoMick, norprovided her personal data to that company.Under the GDPR, Liem and EcoMick’s contract with MarketIQ must include all of thefollowing provisions EXCEPT?

A. Processing the personal data upon documented instructions regarding data transfersoutside of the EEA. 
B. Notification regarding third party requests for access to Liem and EcoMick’s personal data. 
C. Assistance to Liem and EcoMick in their compliance with data protection impact assessments.
D. Returning or deleting personal data after the end of the provision of the services.  



Question # 8

Which of the following is NOT recognized as a common characteristic of cloud computingservices?

A. The service's infrastructure is shared among the supplier's customers and can belocated in a number of countries. 
B. The supplier determines the location, security measures, and service standardsapplicable to the processing. 
C. The supplier allows customer data to be transferred around the infrastructure accordingto capacity.  
D. The supplier assumes the vendor's business risk associated with data processed by the supplier. 



Question # 9

SCENARIOPlease use the following to answer the next question:You have just been hired by a toy manufacturer based in Hong Kong. The company sells abroad range of dolls, action figures and plush toys that can be found internationally in awide variety of retail stores. Although the manufacturer has no offices outside Hong Kongand in fact does not employ any staff outside Hong Kong, it has entered into a number oflocal distribution contracts. The toys produced by the company can be found in all populartoy stores throughout Europe, the United States and Asia. A large portion of the company’srevenue is due to international sales.The company now wishes to launch a new range of connected toys, ones that can talk andinteract 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: onvarious subjects, such as mathematical calculations or the weather. Each figure isequipped with a microphone and speaker and can connect to any smartphone or tablet viaBluetooth. Any mobile device within a 10-meter radius can connect to the toys viaBluetooth as well. The figures can also be associated with other figures (from the samemanufacturer) 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, andthe answer is generated on cloud servers and sent back to the figure. The answer is giventhrough the figure’s integratedspeakers, making it appear as though that the toy is actually responding to the child’sQUESTION. 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 dataprocessing 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 throughwhich 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 figurecome to life onscreen. Each character has its own stock features and abilities, but it is alsopossible to earn additional ones by accomplishing game goals. The only information storedin 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 thecharacter’s abilities remain intact.To ensure GDPR compliance, what should be the company’s position on the issue ofconsent?

A. The child, as the user of the action figure, can provide consent himself, as long as noinformation is shared for marketing purposes. 
B. Written authorization attesting to the responsible use of children’s data would need to beobtained from the supervisory authority. 
C. Consent for data collection is implied through the parent’s purchase of the action figurefor the child. 
D. Parental consent for a child’s use of the action figures would have to be obtained beforeany data could be collected. 



Question # 10

Bioface is a company based in the United States. It has no servers, personnel or assets inthe European Union. By collecting photographs from social media and other web-basedservices, such as newspapers and blogs, it uses machine learning to develop a facialrecognition algorithm. The algorithm identifies individuals in photographs who are not in itsdata set based the algorithm and its existing data. The service collects photographs of datasubjects in the European Union and will identify them if presented with their photographs.Bioface offers its service to government agencies and companies in the United States andCanada, but not to those in the European Union. Bioface does not offer the service toindividuals.Why is Bioface subject to the territorial scope of the General Data Protection Regulation?

A. It collects data from European Union websites, which constitutes an establishment in theEuropean Union. 
B. It offers services in the European Union by identifying data subjects in the European Union. 
C. It collects data from subjects and uses it for automated processing.  
D. It monitors the behavior of data subjects in the European Union.  



Question # 11

Which of the following is NOT a role of works councils? 

A. Determining the monetary fines to be levied against employers for data breach violationsof employee data. 
B. Determining whether to approve or reject certain decisions of the employer that affectemployees. 
C. Determining whether employees’ personal data can be processed or not.  
D. Determining what changes will affect employee working conditions.  



Question # 12

SCENARIOPlease use the following to answer the next question:You have just been hired by a toy manufacturer based in Hong Kong. The company sells abroad range of dolls, action figures and plush toys that can be found internationally in awide variety of retail stores. Although the manufacturer has no offices outside Hong Kongand in fact does not employ any staff outside Hong Kong, it has entered into a number oflocal distribution contracts. The toys produced by the company can be found in all populartoy stores throughout Europe, the United States and Asia. A large portion of the company’srevenue is due to international sales.The company now wishes to launch a new range of connected toys, ones that can talk andinteract 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: onvarious subjects, such as mathematical calculations or the weather. Each figure isequipped with a microphone and speaker and can connect to any smartphone or tablet viaBluetooth. Any mobile device within a 10-meter radius can connect to the toys viaBluetooth as well. The figures can also be associated with other figures (from the samemanufacturer) 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 theanswer is generated on cloud servers and sent back to the figure. The answer is giventhrough the figure’s integratedspeakers, making it appear as though that the toy is actually responding to the child’squestion. 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 dataprocessing 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 throughwhich 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 figurecome to life onscreen. Each character has its own stock features and abilities, but it is alsopossible to earn additional ones by accomplishing game goals. The only information storedin 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 thecharacter’s abilities remain intact.What presents the BIGGEST potential privacy issue with the company’s practices?

A. The NFC portal can read any data stored in the action figures  
B. The information about the data processing involved has not been specified  
C. The cloud service provider is in a country that has not been deemed adequate  
D. The RFID tag in the action figures has the potential for misuse because of the toy’sevolving capabilities 



Question # 13

What must a data controller do in order to make personal data pseudonymous? 

A. Separately hold any information that would allow linking the data to the data subject.  
B. Encrypt the data in order to prevent any unauthorized access or modification.  
C. Remove all indirect data identifiers and dispose of them securely.  
D. Use the data only in aggregated form for research purposes.  



Question # 14

SCENARIOPlease use the following to answer the next question:Jack worked as a Pharmacovigiliance Operations Specialist in the Irish office of amultinational pharmaceutical company on a clinical trial related to COVID-19. As part of hisonboarding process Jack received privacy training He was explicitly informed that while hewould need to process confidential patient data in the course of his work, he may under nocircumstances use this data for anything other than the performance of work-related (asksThis was also specified in the privacy policy, which Jack signed upon conclusion of thetraining.After several months of employment, Jack got into an argument with a patient over thephone. Out of anger he later posted the patient's name and hearth information, along withdisparaging comments, on a social media website. When this was discovered by hisPharmacovigilance supervisors. Jack was immediately dismissedJack's lawyer sent a letter to the company stating that dismissal was a disproportionatesanction, and that if Jack was not reinstated within 14 days his firm would have noalternative but to commence legal proceedings against the company. This letter wasaccompanied by a data access request from Jack requesting a copy of "all personal data,including internal emails that were sent/received by Jack or where Jack is directly orindirectly identifiable from the contents In relation to the emails Jack listed six members ofthe management team whose inboxes he required access.The company conducted an initial search of its IT systems, which returned a large amountof information They then contacted Jack, requesting that he be more specific regardingwhat information he required, so that they could carry out a targeted search Jackresponded by stating that he would not narrow the scope of the information requester.Under Article 82 of the GDPR ("Right to compensation and liability-), which party is liablefor the damage caused by the data breach?

A. Both parties are exempt, as the company is involved in human health research  
B. Jack and the pharmaceutical company are jointly liable.  
C. The pharmaceutical company is liable.  
D. Jack is liable  



Question # 15

Which of the following Convention 108+ principles, as amended in 2018, is NOT consistentwith a principle found in the GDPR?

A. The obligation of companies to declare data breaches.  
B. The requirement to demonstrate compliance to a supervisory authority.  
C. The necessity of the bulk collection of personal data by the government.