Free CIPP-E Mock Exam – Practice Online Confidently

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

SCENARIO Please use the following to answer the next question: Due to rapidly expanding workforce, Company A has decided to outsource its payroll function to Company B. Company B is an established payroll service provider with a sizable client base and a solid reputation in the industry. Company B's payroll solution for Company A relies on the collection of time and attendance data obtained via a biometric entry system installed in each of Company A's factories. Company B won't hold any biometric data itself, but the related data will be uploaded to Company B's UK servers and used to provide the payroll service. Company B's live systems will contain the following information for each of Company A's employees: • Name • Address • Date of Birth • Payroll number • National Insurance number • Sick pay entitlement • Maternity/paternity pay entitlement • Holiday entitlement • Pension and benefits contributions • Trade union contributions Jenny is the compliance officer at Company A. She first considers whether Company A needs to carry out a data protection impact assessment in relation to the new time and attendance system, but isn't sure whether or not this is required. Jenny does know, however, that under the GDPR there must be a formal written agreement requiring Company B to use the time and attendance data only for the purpose of providing the payroll service, and to apply appropriate technical and organizational security measures for safeguarding the data. Jenny suggests that Company B obtain advice from its data protection officer. The company doesn't have a DPO but agrees, in the interest of finalizing the contract, to sign up for the provisions in full. Company A enters into the contract. Weeks later, while still under contract with Company A, Company B embarks upon a separate project meant to enhance the functionality of its payroll service, and engages Company C to help. Company C agrees to extract all personal data from Company B's live systems in order to create a new database for Company B. This database will be stored in a test environment hosted on Company C's U.S. server. The two companies agree not to include any data processing provisions in their services agreement, as data is only being used for IT testing purposes. Unfortunately, Company C's U.S. server is only protected by an outdated IT security system, and suffers a cyber security incident soon after Company C begins work on the project. As a result, data relating to Company A's employees is visible to anyone visiting Company C's website. Company A is unaware of this until Jenny receives a letter from the supervisory authority in connection with the investigation that ensues. As soon as Jenny is made aware of the breach, she notifies all affected employees. The GDPR requires sufficient guarantees of a company's ability to implement adequate technical and organizational measures. What would be the most realistic way that Company B could have fulfilled this requirement?

Through a combination of hardware failure and human error, the decryption key for a bank’s customer account transaction database has been lost. An investigation has determined that this was not the result of hacking or malfeasance, simply an unfortunate combination of circumstances. Which of the following accurately indicates the nature of this incident?

SCENARIO -Please use the following to answer the next question:CreditPlaya, SA is an established Spanish online insurance company whose exclusive activity is providing health insurance for legal residents of Spain, regardless of their nationality.CreditPlaya autonomously manages its own website, through which a potential customer, engaging in a free pre-contractual activity, enters his or her full name, e-mail address, tax identification number (to verify residence in Spain), age, profession, and the full names of any other adult members of his or her family.With this data, CreditPlaya immediately sends an email granting or denying eligibility for a health insurance policy. In the case of eligibility, the email also contains the eventual cost of the policy and two PDF documents – one with the contractual Terms and Conditions, and the other with the privacy notice as required by Article 13 of the GDPR.The CreditPlaya Information Tracking System (ITS) is very efficient, with a low rate of unpaid insurance policies. The ITS is automatically fed by the information provided by every applicant, whose data is then used to refine insurance policy rates.To ensure their back-up procedures, in January 2021 CreditPlaya started sending weekly copies of the whole database with all the applicants' personal data to an independent company in Uruguay. The information was sent through state-of-the-art encrypting tools, but once in Uruguay was stored without any encryption method.In March 2022, the entire data base stored on the Uruguay's company servers was encrypted by malicious ransomware. There was no evidence that the data was accessed by unauthorized persons, much less altered or exfiltrated. Despite the incident, CreditPlaya found that they could rely on the locally based Spanish back-up information and carry on its activity without interrupting its operations. The incident caused the termination of the professional relationship between the two companies.The content of the email that CreditPlaya sends does not comply with GDPR requirements because it lacks what?

The European Data Protection Board (EDPB) recommends measures to supplement transfer tools, in order to ensure compliance with the European Union (EU) level of personal data protection. According to these recommendations, what additional actions should be taken when a transfer to a third country is based upon an adequacy decision?