IAPP CIPP-E Exam Dumps - Actual Questions Answers

According to Article 35 of the GDPR, the controller must carry out a data protection impact assessment (DPIA) prior to processing that is likely to result in a high risk to the rights and freedoms of natural persons. The DPIA is a process for assessing and mitigating the potential impact of the processing on the protection of personal data. The controller must seek the advice of the DPO, where designated, when carrying out a DPIA. The DPO can assist the controller in conducting the DPIA and ensuring its compliance with the GDPR requirements. The DPO can also monitor the performance of the DPIA and act as a contact point for the supervisory authority and the data subjects. References:

Article 35 of the GDPR

European Data Protection Law & Practice textbook, Chapter 7: Data Protection Impact Assessment, Section 7.2: When is a DPIA required?, Subsection 7.2.1: The role of the DPO

Roles and Responsibilities of a Data Protection Officer

The Universal Declaration of Human Rights (UDHR) was adopted by the United Nations General Assembly in 1948 as a response to the atrocities of World War II. It is considered the first global expression of human rights and fundamental freedoms. Article 12 of the UDHR states that “No one shall be subjected to arbitrary interference with his privacy, family, home or correspondence, nor to attacks upon his honour and reputation. Everyone has the right to the protection of the law against such interference or attacks.” This article is the origin of privacy as a fundamental human right that has influenced many subsequent international and regional instruments, such as the European Convention of Human Rights (ECHR), the OECD Guidelines on the Protection of Privacy, and the Charter of Fundamental Rights of the European Union (CFREU). References:

IAPP CIPP/E Study Guide, page 7

[Universal Declaration of Human Rights]

[Article 12 of the UDHR]

According to the GDPR, pseudonymization is a technique that reduces the linkability of personal data to a specific data subject by replacing identifying attributes with pseudonyms1. Pseudonymization is not a sufficient measure to anonymize personal data, which means that the data cannot be attributed to an identifiable person without additional information2. Pseudonymization can help data controllers and processors to comply with the GDPR principles of data minimization, purpose limitation, and storage limitation, as well as to enhance the security and confidentiality of personal data3.

In this scenario, JaphSoft’s use of pseudonymization is not in compliance with the GDPR because of option C: JaphSoft was in possession of information that could be used to identify data subjects. This is because JaphSoft did not keep the additional information (the contact information) separately from the pseudonymized data (the identifying information), and did not apply technical and organizational measures to prevent the re-identification of the data subjects4. This means that JaphSoft could potentially link the personal data to the individuals, and therefore, the data was not effectively pseudonymized. Moreover, JaphSoft did not have a deletion process for the data it received from clients, which could violate the principle of storage limitation that requires personal data to be kept no longer than necessary for the purposes for which they are processed.