[Jan-2026] The Best Certified Information Privacy Professional CIPP-E Professional Exam Questions [Q154-Q169]

15Jan 2026 by admin No Comments

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[Jan-2026] The Best Certified Information Privacy Professional CIPP-E Professional Exam Questions

Try 100% Updated CIPP-E Exam Questions [2026]

Achieving CIPP-E certification is a significant achievement for privacy professionals who are looking to advance their careers. It demonstrates a high level of knowledge and expertise in the field of data protection and can open up new opportunities for career progression. Additionally, maintaining the certification requires ongoing education and training, ensuring that certified professionals stay up-to-date with the latest developments in data protection laws and regulations.

The CIPP-E exam is developed and administered by the International Association of Privacy Professionals (IAPP), which is the largest and most respected global privacy organization. CIPP-E exam is based on the IAPP’s Body of Knowledge, which is a comprehensive framework that covers the various domains of privacy and data protection. The CIPP-E certification is recognized by organizations worldwide as a mark of excellence in privacy and data protection, and it is a valuable credential for individuals who want to advance their careers in the field.

QUESTION 154
Which GDPR principle would a Spanish employer most likely depend upon to annually send the personal data of its employees to the national tax authority?

The consent of the employees.

The legal obligation of the employer.

The legitimate interest of the public administration.

The protection of the vital interest of the employees.

According to Article 6 of the GDPR, the processing of personal data is only lawful if and to the extent that at least one of the following applies:
* the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
* processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
* processing is necessary for compliance with a legal obligation to which the controller is subject;
* processing is necessary in order to protect the vital interests of the data subject or of another natural person;
* processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
* processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
In this case, the Spanish employer would most likely depend on the legal obligation of the employer as the lawful basis for sending the personal data of its employees to the national tax authority. This is because the employer is subject to the tax laws and regulations of Spain, which require the employer to report the income and deductions of its employees to the tax authority on an annual basis. The employer must comply with this legal obligation, and the processing of the employees’ personal data is necessary for this purpose. The employer does not need to obtain the consent of the employees, as consent is not a valid basis for processing personal data where there is a clear imbalance between the data subject and the controller, such as in the context of employment. The employer also does not need to rely on the legitimate interest of the public administration, as this is not a specific purpose for which the employer is processing the personal data, but rather a general interest that may be served by the tax authority. The employer also does not need to invoke the protection of the vital interest of the employees, as this basis only applies in situations where the processing is necessary to protect someone’s life, such as in a medical emergency. References: Article 6 GDPR – Lawfulness of processing – General Data Protection Regulation (GDPR), Lawful basis for processing
| ICO, Legal obligation as a lawful basis for processing personal data under the GDPR, [Consent in the employment context | ICO], [Vital interests | ICO]

QUESTION 155
What type of data lies beyond the scope of the General Data Protection Regulation?

Pseudonymized

Anonymized

Encrypted

Masked

QUESTION 156
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?

Adopt a supplementary data transfer mechanism.

Monitor the ongoing validity of the data transfer mechanism.

Adopt technical, contractual or organizational supplementary measures.

Monitor changes in the law or practice of the third country that would tower the level of protection of personal data

An adequacy decision is a decision adopted by the European Commission, which determines that a third country, a territory or one or more specified sectors within a third country, or an international organisation ensures an adequate level of protection of personal data1. This means that the third country or organisation provides a level of protection that is essentially equivalent to that guaranteed within the European Union (EU), taking into account its domestic law and international commitments, as well as the respect for the rule of law, human rights and fundamental freedoms, relevant legislation, and the existence and effective functioning of independent supervisory authorities1. An adequacy decision is one of the transfer tools that can be used to transfer personal data to a third country or organisation without requiring any further authorisation1. However, an adequacy decision is not permanent and can be amended, suspended or repealed by the Commission at any time, if the conditions are no longer met1. Therefore, according to the recommendations of the European Data Protection Board (EDPB), the additional action that should be taken when a transfer to a third country is based upon an adequacy decision is to monitor changes in the law or practice of the third country that would lower the level of protection of personal data2. This means that the data exporter should stay informed of any developments in the third country or organisation that could affect the validity of the adequacy decision, and take appropriate measures if the level of protection is no longer adequate2. The data exporter should also cooperate with the competent supervisory authority and inform it of any issues that may affect the compliance with the adequacy decision2. Therefore, option D is the correct answer. Reference: Art. 45 GDPR – Transfers on the basis of an adequacy decision, Recommendations 01/2020 on measures that supplement transfer tools to ensure compliance with the EU level of protection of personal data

QUESTION 157
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.
Under the GDPR, which of Company B’s actions would NOT be likely to trigger a potential enforcement action?

Their omission of data protection provisions in their contract with Company C.

Their failure to provide sufficient security safeguards to Company A’s data.

Their engagement of Company C to improve their payroll service.

Their decision to operate without a data protection officer.

QUESTION 158
Many businesses print their employees’ photographs on building passes, so that employees can be identified by security staff. This is notwithstanding the fact that facial images potentially qualify as biometric data under the GDPR. Why would such practice be permitted?

Because use of biometric data to confirm the unique identification of data subjects benefits from an exemption.

Because photographs qualify as biometric data only when they undergo a “specific technical processing”.

Because employees are deemed to have given their explicit consent when they agree to be photographed by their employer.

Because photographic ID is a physical security measure which is “necessary for reasons of substantial public interest”.

QUESTION 159
SCENARIO
Please use the following to answer the next question:
Financially, it has been a very good year at ARRA Hotels: Their 21 hotels, located in Greece (5), Italy (15) and Spain (1), have registered their most profitable results ever. To celebrate this achievement, ARRA Hotels’ Human Resources office, based in ARRA’s main Italian establishment, has organized a team event for its 420 employees and their families at its hotel in Spain.
Upon arrival at the hotel, each employee and family member is given an electronic wristband at the reception desk. The wristband serves a number of functions:
. Allows access to the “party zone” of the hotel, and emits a buzz if the user approaches any unauthorized areas
. Allows up to three free drinks for each person of legal age, and emits a buzz once this limit has been reached
. Grants a unique ID number for participating in the games and contests that have been planned.
Along with the wristband, each guest receives a QR code that leads to the online privacy notice describing the use of the wristband. The page also contains an unchecked consent checkbox. In the case of employee family members under the age of 16, consent must be given by a parent.
Among the various activities planned for the event, ARRA Hotels’ HR office has autonomously set up a photocall area, separate from the main event venue, where employees can come and have their pictures taken in traditional carnival costume.
The photos will be posted on ARRA Hotels’ main website for general marketing purposes.
On the night of the event, an employee from one of ARRA’s Greek hotels is displeased with the results of the photos in which he appears. He intends to file a complaint with the relevant supervisory authority in regard to the following:
. The lack of any privacy notice in the separate photocall area
The unlawful cross-border processing of his personal data
. The unacceptable aesthetic outcome of his photos
Assuming that there is a cross-border processing of personal data, which of the following criteria would NOT be useful to the lead supervisory authority responsible for the Greek employee’s complaint when trying to determine the location of the controller’s main establishment?

Where the controller is registered as a company.

Where the processor is registered as a company.

Where decisions about the processing activities are made.

Where the director with responsibility for processing activities is located.

QUESTION 160
When does the European Data Protection Board (EDPB) recommend reevaluating whether a transfer tool is effectively providing a level of personal data protection that is in compliance with the European Union (EU) level?

After a personal data breach.

Every three (3) years.

On an ongoing basis.

Every year.

QUESTION 161
Data retention in the EU was underpinned by a legal framework established by the Data Retention Directive (2006/24/EC). Why is the Directive no longer part of EU law?

The Directive was superseded by the EU Directive on Privacy and Electronic Communications.

The Directive was superseded by the General Data Protection Regulation.

The Directive was annulled by the Court of Justice of the European Union.

The Directive was annulled by the European Court of Human Rights.

QUESTION 162
What is the key difference between the European Council and the Council of the European Union?

The Council of the European Union is helmed by a president.

The Council of the European Union has a degree of legislative power.

The European Council focuses primarily on issues involving human rights.

The European Council is comprised of the heads of each EU member state.

QUESTION 163
SCENARIO
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 questionnaires, 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 questionnaires 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 for TripBliss 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.
If TripBliss Inc. decides not to report the incident to the supervisory authority, what would be their BEST defense?

The resulting obligation to notify data subjects would involve disproportionate effort.

The incident resulted from the actions of a third-party that were beyond their control.

The destruction of the stolen data makes any risk to the affected data subjects unlikely.

The sensitivity of the categories of data involved in the incident was not substantial enough.

QUESTION 164
When is data sharing agreement MOST likely to be needed?

When anonymized data is being shared.

When personal data is being shared between commercial organizations acting as joint data controllers.

When personal data is being proactively shared by a controller to support a police investigation.

When personal data is being shared with a public authority with powers to require the personal data to be disclosed.

QUESTION 165
A private company has establishments in France, Poland, the United Kingdom and, most prominently, Germany, where its headquarters is established. The company offers its services worldwide. Most of the services are designed in Germany and supported in the other establishments. However, one of the services, a Software as a Service (SaaS) application, was defined and implemented by the Polish establishment. It is also supported by the other establishments.
What is the lead supervisory authority for the SaaS service?

The supervisory authority of Germany at federal level.

The supervisory authority of Germany at regional level.

The supervisory authority of the Republic of Poland.

The supervisory authority of the European Union.

QUESTION 166
Under what circumstances would the GDPR apply to personal data that exists in physical form, such as information contained in notebooks or hard copy files?

Only where the personal data is produced as a physical output of specific automated processing activities, such as printing, labelling, or stamping.

Only where the personal data is to be subjected to specific computerized processing, such as image scanning or optical character recognition.

Only where the personal data is treated by automated means in some way, such as computerized distribution or filing.

Only where the personal data is handled in a sufficiently structured manner so as to form part of a filing system.

QUESTION 167
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.
Before Anna determines whether Frank’s performance database is permissible, what additional information does she need?

More information about Frank’s data protection training.

More information about the extent of the information loss.

More information about the algorithm Frank used to mask student numbers.

More information about what students have been told and how the research will be used.

QUESTION 168
Under Article 80(1) of the GDPR, individuals can elect to be represented by not-for-profit organizations in a privacy group litigation or class action. These organizations are commonly known as?

Law firm organizations.

Civil society organizations.

Human rights organizations.

Constitutional rights organizations.

QUESTION 169
Which GDPR requirement will present the most significant challenges for organizations with Bring Your Own Device (BYOD) programs?

Data subjects must be sufficiently informed of the purposes for which their personal data is processed.

Processing of special categories of personal data on a large scale requires appointing a DPO.

Personal data of data subjects must always be accurate and kept up to date.

Data controllers must be in control of the data they hold at all times.

CIPP-E Exam Questions Get Updated [2026] with Correct Answers: https://www.practicematerial.com/CIPP-E-exam-materials.html

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