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PECB Certified Data Protection Officer Sample Questions (Q77-Q82):
NEW QUESTION # 77
Scenario:
Pinky, a retail company,received a requestfrom adata subjectto identify which purchasesthey had madeat differentphysical store locations. However,Pinky does not link purchase records to customer identities, since purchasesdo not require account creation.
Question:
Should Pinkyprocess additional informationfrom customers in order toidentify the data subjectas requested?
- A. No, Pinky isnot requiredto process additional information, since the processing of personal data in this case does not require Pinky toidentify the data subject.
- B. Yes, Pinky is required tomaintain, acquire, or process additional informationin order to identify the data subject.
- C. Yes, Pinky is required to process additional information for the purpose ofexercising the data subject' s rightscovered inArticles 15-21 of GDPR.
- D. No, but Pinky must ask the data subject to provide further evidence proving their identity.
Answer: A
Explanation:
UnderArticle 11(1) of GDPR, controllersare not required to process additional datafor the sole purpose of identifying data subjectsif such identification is not needed for processing.
* Option C is correctbecausePinky does not store identifiable purchase data, so it is not required to create additional records.
* Option A and B are incorrectbecauseGDPR does not obligate controllers to process additional data if identification is unnecessary.
* Option D is incorrectbecausePinky cannot require additional information when it does not have a basis to process identity-linked data.
References:
* GDPR Article 11(1)(Controllers are not required to process extra data for identification)
* Recital 57(Data controllers should avoid collecting unnecessary identity data)
NEW QUESTION # 78
Question:
Organization XYZ has just appointed aDPO. As such, XYZ needs toestablish the DPO's rolein the employment contract.
Which of the statements belowholds true?
- A. The DPO acts as acontact pointbetween thecontroller and the processor.
- B. The DPO acts as acontact pointbetween the organization'stop management and employees.
- C. The DPO acts as acontact pointbetween thesupervisory authoritiesand the controller.
- D. The DPO acts as adecision-makeron all data processing activities.
Answer: C
Explanation:
UnderArticle 39(1)(e) of GDPR, theDPO acts as a contact point for supervisory authoritiesand must be readily accessible for regulatory inquiries and investigations.
* Option A is correctbecauseGDPR explicitly states that the DPO serves as a liaison between the organization and the supervisory authority.
* Option B is incorrectbecausethe controller and processor are independent entities under GDPR, and the DPO does not facilitate their relationship.
* Option C is incorrectbecausethe DPO does not act as a communication channel for internal company matters.
* Option D is incorrectbecauseDPOs advise and monitor but do not make operational decisions.
References:
* GDPR Article 39(1)(e)(DPO is a contact point for the supervisory authority)
* Recital 97(DPO's role in ensuring compliance)
NEW QUESTION # 79
Scenario:
ChatBubbleis a software company that stores personal data, includingusernames, emails, and passwords.
Last month, an attacker gained access to ChatBubble's system, but the personal datawas encrypted, preventing unauthorized access.
Question:
Should thedata subjects be notifiedin this case?
- A. Yes, but only if the supervisory authority explicitly requests notification.
- B. No, the company isnot required to notify data subjectsabout a data breach that affects alarge number of individuals.
- C. Yes, the company shall communicateall incidentsregarding personal data to the data subjects.
- D. No, the company isnot required to notify data subjects when the personal data is protected with appropriate technical and organizational measures.
Answer: D
Explanation:
UnderArticle 34(3)(a) of GDPR, if personal datais encrypted or otherwise protected, notification to data subjectsis not requiredunless the risk is high.
* Option C is correctbecauseencryption renders the data unintelligible to unauthorized parties, reducing risk.
* Option A is incorrectbecausenot all breaches require data subject notification-only those posing high risks.
* Option B is incorrectbecausethe number of affected individuals does not determine notification requirements.
* Option D is incorrectbecausenotification is based on risk assessment, not supervisory authority requests alone.
References:
* GDPR Article 34(3)(a)(No notification required if encryption makes data inaccessible)
* Recital 86(Notification is necessary only if data loss poses a significant risk)
NEW QUESTION # 80
Scenario:
PickFoodis an onlinefood delivery servicethat allows customers to order foodonlineand pay bycredit card.
Thepayment serviceis provided byPaySmart, which processes the transactions.
Question:
According toArticle 30 of GDPR, whattype of information should PaySmart NOT maintainwhen recording online transaction processing activity?
- A. Alist of customers' transaction amounts and items purchased.
- B. Transfers of personal data tothird-party payment processors.
- C. Theexpected time for personal data erasure.
- D. Thegeneral descriptionof technical data protection measures.
Answer: A
Explanation:
UnderArticle 30(1) of GDPR, controllers and processors must document details such asdata processing purposes, categories of data subjects, and security measures, butdo not need to store detailed transaction amounts or items purchasedunless required for compliance.
* Option D is correctbecausedetailed transactional information is not a mandatory requirement in the processing records.
* Option A is incorrectbecausesecurity measures must be documented.
* Option B is incorrectbecausedata retention periods must be includedin records.
* Option C is incorrectbecausecross-border data transfers must be documented.
References:
* GDPR Article 30(1)(f)(Controllers must document data transfers)
* Recital 82(Record-keeping requirements for accountability)
NEW QUESTION # 81
Scenario3:
COR Bank is an international banking group that operates in 31 countries. It was formed as the merger of two well-known investment banks in Germany. Their two main fields of business are retail and investment banking. COR Bank provides innovative solutions for services such as payments, cash management, savings, protection insurance, and real-estate services. COR Bank has a large number of clients and transactions.
Therefore, they process large information, including clients' personal data. Some of the data from the application processes of COR Bank, including archived data, is operated by Tibko, an IT services company located in Canada. To ensure compliance with the GDPR, COR Bank and Tibko have reached a data processing agreement Basedon the agreement, the purpose and conditions of data processing are determined by COR Bank. However, Tibko is allowed to make technical decisions for storing the data based on its own expertise. COR Bank aims to remain a trustworthy bank and a long-term partner for its clients. Therefore, they devote special attention to legal compliance. They started the implementation process of a GDPR compliance program in 2018. The first step was to analyze the existing resources and procedures. Lisa was appointed as the data protection officer (DPO). Being the information security manager of COR Bank for many years, Lisa had knowledge of the organization's core activities. She was previously involved in most of the processes related to information systems management and data protection. Lisa played a key role in achieving compliance to the GDPR by advising the company regarding data protection obligations and creating a data protection strategy. After obtaining evidence of the existing data protection policy, Lisa proposed to adapt the policy to specific requirements of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of departments. As the DPO, she had access to several departments, including HR and Accounting Department. This assured the organization that there was a continuous cooperation between them. The activities of some departments within COR Bank are closely related to data protection. Therefore, considering their expertise, Lisa was advised from the top management to take orders from the heads of those departments when taking decisions related to their field. Based on this scenario, answer the following question:
Question:
According to scenario 3,Tibko stores archived data on behalf of COR Bank. This means that Tibko is a:
- A. Joint controller with COR Bank, since they archive COR Bank's data and take technical decisions regarding data protection.
- B. Data controller, since they control some of the data from the application processes of COR Bank.
- C. Data processor, since they store COR Bank's data based on the purpose and conditions defined by COR Bank.
- D. Independent controller, since Tibko handles data security and storage.
Answer: C
Explanation:
UnderArticle 4(8) of GDPR, adata processorprocesses personal dataon behalf of a controlleranddoes not determinethe purpose of processing. Tibkoonly stores and managesdata butdoes not decidewhy it is processed.
* Option B is correctbecause Tibko acts as aprocessorfor COR Bank.
* Option A is incorrectbecause Tibkodoes not determine data processing purposes.
* Option C is incorrectbecausejoint controllersmust jointly decide on processing purposes.
* Option D is incorrectbecauseTibko does not act as an independent controller.
References:
* GDPR Article 4(8)(Definition of a processor)
* GDPR Article 28(Processor obligations)
NEW QUESTION # 82
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