GDPR Latest Exam Pattern - The Best PECB GDPR Exam Question: PECB Certified Data Protection Officer
GDPR Latest Exam Pattern - The Best PECB GDPR Exam Question: PECB Certified Data Protection Officer
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PECB GDPR Exam Syllabus Topics:
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PECB Certified Data Protection Officer Sample Questions (Q51-Q56):
NEW QUESTION # 51
Scenario1:
MED is a healthcare provider located in Norway. It provides high-quality and affordable healthcare services, including disease prevention, diagnosis, and treatment. Founded in 1995, MED is one of the largest health organizations in the private sector. The company has constantly evolved in response to patients' needs.
Patients that schedule an appointment in MED's medical centers initially need to provide their personal information, including name, surname, address, phone number, and date of birth. Further checkups or admission require additional information, including previous medical history and genetic data. When providing their personal data, patients are informed that the data is used for personalizing treatments and improving communication with MED's doctors. Medical data of patients, including children, are stored in the database of MED's health information system. MED allows patients who are at least 16 years old to use the system and provide their personal information independently. For children below the age of 16, MED requires consent from the holder of parental responsibility before processing their data.
MED uses a cloud-based application that allows patients and doctors to upload and access information.
Patients can save all personal medical data, including test results, doctor visits, diagnosis history, and medicine prescriptions, as well as review and track them at any time. Doctors, on the other hand, can access their patients' data through the application and can add information as needed.
Patients who decide to continue their treatment at another health institution can request MED to transfer their data. However, even if patients decide to continue their treatment elsewhere, their personal data is still used by MED. Patients' requests to stop data processing are rejected. Thisdecision was made by MED's top management to retain the information of everyone registered in their databases.
The company also shares medical data with InsHealth, a health insurance company. MED's data helps InsHealth create health insurance plans that meet the needs of individuals and families.
MED believes that it is its responsibility to ensure the security and accuracy of patients' personal data. Based on the identified risks associated with data processing activities, MED has implemented appropriate security measures to ensure that data is securely stored and processed.
Since personal data of patients is stored and transmitted over the internet, MED uses encryption to avoid unauthorized processing, accidental loss, or destruction of data. The company has established a security policy to define the levels of protection required for each type of information and processing activity. MED has communicated the policy and other procedures to personnel and provided customized training to ensure proper handling of data processing.
Question:
Considering the nature of data processing activities described in scenario 1, is GDPR applicable to MED?
- A. No, MED's activities include healthcare services within one of the four EFTA states, which do not fall under the scope of GDPR.
- B. Yes, MED's use of cloud-based software to store and process health-related information necessitates compliance with GDPR's data protection requirements.
- C. No, because MED operates only in Norway, and GDPR does not apply to domestic processing.
- D. Yes, GDPR is applicable to MED due to its processing activities involving personal information.
Answer: D
Explanation:
GDPR applies to any organization that processes personal data of individuals within theEuropean Economic Area (EEA), regardless of the organization's location. Since MED is based in Norway, which is an EEA country, and processes personal health data, it must comply with GDPR.
Option Ais correct because GDPR applies to all controllers and processors within the EEA.Option Bis misleading because while cloud-based software is relevant, the primary reason GDPR applies is MED's processing of personal data.Option Cis incorrect because EFTA states (including Norway) are subject to GDPR.Option Dis incorrect because GDPR applies to all personal data processing in the EEA.
References:
* GDPR Article 3(Territorial Scope)
* Recital 22(GDPR applies to EEA countries)
NEW QUESTION # 52
Scenario:2
Soyled is a retail company that sells a wide range of electronic products from top European brands. It primarily sells its products in its online platforms (which include customer reviews and ratings), despite using physical stores since 2015. Soyled's website and mobile app are used by millions of customers. Soyled has employed various solutions to create a customer-focused ecosystem and facilitate growth. Soyled uses customer relationship management (CRM) software to analyze user data and administer the interaction with customers. The software allows the company to store customer information, identify sales opportunities, and manage marketing campaigns. It automatically obtains information about each user's IP address and web browser cookies. Soyled also uses the software to collect behavioral data, such as users' repeated actions and mouse movement information. Customers must create an account to buy from Soyled's online platforms. To do so, they fill out a standard sign-up form of three mandatory boxes (name, surname, email address) and a non-mandatory one (phone number). When the user clicks the email address box, a pop-up message appears as follows: "Soyled needs your email address to grant you access to your account and contact you about any changes related to your account and our website. For further information, please read our privacy policy.' When the user clicks the phone number box, the following message appears: "Soyled may use your phone number to provide text updates on the order status. The phone number may also be used by the shipping courier." Once the personal data is provided, customers create a username and password, which are used to access Soyled's website or app. When customers want to make a purchase, they are also required to provide their bank account details. When the user finally creates the account, the following message appears: "Soyled collects only the personal data it needs for the following purposes: processing orders, managing accounts, and personalizing customers' experience. The collected data is shared with our network and used for marketing purposes." Soyled uses personal data to promote sales and its brand. If a user decides to close the account, the personal data is still used for marketing purposes only. Last month, the company received an email from John, a customer, claiming that his personal data was being used for purposes other than those specified by the company. According to the email, Soyled was using the data for direct marketing purposes. John requested details on how his personal data was collected, stored, and processed. Based on this scenario, answer the following question:
Question:
Based on scenario2, Soyled only has threemandatory fieldsin its sign-up form. On which GDPR principle is this decision based?
- A. Purpose limitation
- B. Lawfulness, fairness, and transparency
- C. Storage limitation
- D. Data minimization
Answer: D
Explanation:
UnderArticle 5(1)(c) of GDPR, thedata minimization principlestates that personal data must beadequate, relevant, and limited to what is necessaryfor processing.
Soyled'sdecision to have only three mandatory fields(name, surname, and email) aligns withdata minimizationsince itonly collects the minimum data neededfor account creation.Option C is correct.
Option Ais incorrect as transparency relates to informing users.Option Bis incorrect because purpose limitation focuses on using data only for specific purposes.Option Dis incorrect because storage limitation concernsdata retention periods.
References:
* GDPR Article 5(1)(c)(Data minimization principle)
* Recital 39(Limiting data collection to necessity)
NEW QUESTION # 53
Scenario6:
Bus Spot is one of the largest bus operators in Spain. The company operates in local transport and bus rental since 2009. The success of Bus Spot can be attributed to the digitization of the bus ticketing system, through which clients can easily book tickets and stay up to date on any changes to their arrival or departure time. In recent years, due to the large number of passengers transporteddaily. Bus Spot has dealt with different incidents including vandalism, assaults on staff, and fraudulent injury claims. Considering the severity of these incidents, the need for having strong security measures had become crucial. Last month, the company decided to install a CCTV system across its network of buses. This security measure was taken to monitor the behavior of the company's employees and passengers, enabling crime prevention and ensuring safety and security. Following this decision, Bus Spot initiated a data protection impact assessment (DPIA). The outcome of each step of the DPIA was documented as follows: Step 1: In all 150 buses, two CCTV cameras will be installed. Only individuals authorized by Bus Spot will have access to the information generated by the CCTV system. CCTV cameras capture images only when the Bus Spot's buses are being used. The CCTV cameras will record images and sound. The information is transmitted to a video recorder and stored for 20 days. In case of incidents, CCTV recordings may be stored for more than 40 days and disclosed to a law enforcement body. Data collected through the CCTV system will be processed bv another organization. The purpose of processing this tvoe of information is to increase the security and safety of individuals and prevent criminal activity. Step 2: All employees of Bus Spot were informed for the installation of a CCTV system. As the data controller, Bus Spot will have the ultimate responsibility to conduct the DPIA. Appointing a DPO at that point was deemed unnecessary. However, the data processor's suggestions regarding the CCTV installation were taken into account. Step 3: Risk Likelihood (Unlikely, Possible, Likely) Severity (Moderate, Severe, Critical) Overall risk (Low, Medium, High) There is a risk that the principle of lawfulness, fairness, and transparency will be compromised since individuals might not be aware of the CCTV location and its field of view. Likely Moderate Low There is a risk that the principle of integrity and confidentiality may be compromised in case the CCTV system is not monitored and controlled with adequate security measures.
Possible Severe Medium There is a risk related to the right of individuals to be informed regarding the installation of CCTV cameras. Possible Moderate Low Step 4: Bus Spot will provide appropriate training to individuals that have access to the information generated by the CCTV system. In addition, it will ensure that the employees of the data processor are trained as well. In each entrance of the bus, a sign for the use of CCTV will be displayed. The sign will be visible and readable by all passengers. It will show other details such as the purpose of its use, the identity of Bus Spot, and its contact number in case there are any queries.
Only two employees of Bus Spot will be authorized to access the CCTV system. They will continuously monitor it and report any unusual behavior of bus drivers or passengers to Bus Spot. The requests of individuals that are subject to a criminal activity for accessing the CCTV images will be evaluated only for a limited period of time. If the access is allowed, the CCTV images will be exported by the CCTV system to an appropriate file format. Bus Spot will use a file encryption software to encrypt data before transferring onto another file format. Step 5: Bus Spot's top management has evaluated the DPIA results for the processing of data through CCTV system. The actions suggested to address the identified risks have been approved and will be implemented based on best practices. This DPIA involves the analysis of the risks and impacts in only a group of buses located in the capital of Spain. Therefore, the DPIA will be reconducted for each of Bus Spot's buses in Spain before installing the CCTV system. Based on this scenario, answer the following question:
Question:
Which step of theDPIA methodologydid Bus Spotmisswhen conducting the DPIA?
- A. Thenecessity and proportionality evaluationstep, where it should have determined thelawful basis for data processing.
- B. Thesupervisory authority approvalstep, where it should have obtained prior authorization before implementing the CCTV system.
- C. The stepdescribing the data processing activities, where it should have detailed thescope, nature, context, and purposes of the processing.
- D. Thealignment with GDPR-defined DPIA guidelines, where it should have adhered to the regulatory framework and methodology outlined by the GDPR.
Answer: A
Explanation:
UnderArticle 35(7)(b) of GDPR, a DPIA must include an assessment of thenecessity and proportionality of processing. This ensures that data processingis lawful, limited, and justified. Bus Spotmissed this step, which is essential for verifyingthe lawful basis for processing CCTV data.
* Option A is correctbecause thenecessity and proportionality assessment was required but not completed.
* Option B is incorrectbecause Bus Spotdocumented data processing activities in the DPIA.
* Option C is incorrectbecausenot aligning with GDPR guidelines does not automatically invalidate a DPIA.
* Option D is incorrectbecauseprior approval from a supervisory authority is only required if high- risk processing is detected without sufficient mitigation measures(Article 36).
References:
* GDPR Article 35(7)(b)(Necessity and proportionality in DPIAs)
* Recital 90(Assessing necessity in a DPIA)
NEW QUESTION # 54
Scenario:2
Soyled is a retail company that sells a wide range of electronic products from top European brands. It primarily sells its products in its online platforms (which include customer reviews and ratings), despite using physical stores since 2015. Soyled's website and mobile app are used by millions of customers. Soyled has employed various solutions to create a customer-focused ecosystem and facilitate growth. Soyled uses customer relationship management (CRM) software to analyze user data and administer the interaction with customers. The software allows the company to store customer information, identify sales opportunities, and manage marketing campaigns. It automatically obtains information about each user's IP address and web browser cookies. Soyled also uses the software to collect behavioral data, such as users' repeated actions and mouse movement information. Customers must create an account to buy from Soyled's online platforms. To do so, they fill out a standard sign-up form of three mandatory boxes (name, surname, email address) and a non-mandatory one (phone number). When the user clicks the email address box, a pop-up message appears as follows: "Soyled needs your email address to grant you access to your account and contact you about any changes related to your account and our website. For further information, please read our privacy policy.' When the user clicks the phone number box, the following message appears: "Soyled may use your phone number to provide text updates on the order status. The phone number may also be used by the shipping courier." Once the personal data is provided, customers create a username and password, which are used to access Soyled's website or app. When customers want to make a purchase, they are also required to provide their bank account details. When the user finally creates the account, the following message appears: "Soyled collects only the personal data it needs for the following purposes: processing orders, managing accounts, and personalizing customers' experience. The collected data is shared with our network and used for marketing purposes." Soyled uses personal data to promote sales and its brand. If a user decides to close the account, the personal data is still used for marketing purposes only. Last month, the company received an email from John, a customer, claiming that his personal data was being used for purposes other than those specified by the company. According to the email, Soyled was using the data for direct marketing purposes. John requested details on how his personal data was collected, stored, and processed. Based on this scenario, answer the following question:
Question:
Based on scenario2, is John's request eligible under GDPR?
- A. No, data subjects can request access to how their data is being collected but not details about its processing or storage.
- B. Yes, data subjects have theright to request detailson how their personal data is collected, stored, and processed.
- C. No, because John's data was collected based on legitimate interest.
- D. No, data subjects are not eligible to request details on the collection, storage, or processing of their personal data.
Answer: B
Explanation:
UnderArticle 15 of GDPR, theRight of Accessallows data subjects torequest detailed informationabout:
* The purpose of data processing
* Categories of personal data collected
* Data recipients
* Storage duration
* Rights to rectification and erasure
John's request isvalid under GDPR, makingOption C correct.Option Ais incorrect because GDPR grants full transparency.Option Bis incorrect because data subjectsmustbe informed upon request.Option Dis incorrect becauselawful basis does not override access rights.
References:
* GDPR Article 15(Right of Access)
* Recital 63(Transparency in personal data processing)
NEW QUESTION # 55
Scenario 7: EduCCS is an online education platform based in Netherlands. EduCCS helps organizations find, manage, and deliver their corporate training. Most of EduCCS's clients are EU residents. EduCCS is one of the few education organizations that have achieved GDPR compliance since 2019. Their DPO is a full-time employee who has been engaged in most data protection processes within the organization. In addition to facilitating GDPR compliance, the DPO acts as an intermediary point between EduCCS and other relevant interested parties. EduCCS's users can benefit from the variety of up-to-date training library and the possibility of accessing it through their phones, tablets, or computers. EduCCS's services are offered through two main platforms: online learning and digital training. To use one of these platforms, users should sign on EduCCS's website by providing their personal information. Online learning is a platform in which employees of other organizations can search for and request the training they need. Through its digital training platform, on the other hand, EduCCS manages the entire training and education program for other organizations.
Organizations that need this type of service need to provide information about their core activities and areas where training sessions are needed. This information is then analyzed by EduCCS and a customized training program is provided. In the beginning, all IT-related services were managed by two employees of EduCCS.
However, after acquiring a large number of clients, managing these services became challenging That is why EduCCS decided to outsource the IT service function to X-Tech. X-Tech provides IT support and is responsible for ensuring the security of EduCCS's network and systems. In addition, X-Tech stores and archives EduCCS's information including their training programs and clients' and employees' data. Recently, X-Tech made headlines in the technology press for being a victim of a phishing attack. A group of three attackers hacked X-Tech's systems via a phishing campaign which targeted the employees of the Marketing Department. By compromising X-Tech's mail server, hackers were able to gain access to more than 200 computer systems. Consequently, access to the networks of EduCCS's clients was also allowed. Using EduCCS's employee accounts, attackers installed a remote access tool on EduCCS'scompromised systems. By doing so, they gained access to personal information of EduCCS's clients, training programs, and other information stored in its online payment system. The attack was detected by X-Tech's system administrator.
After detecting unusual activity in X-Tech's network, they immediately reported it to the incident management team of the company. One week after being notified about the personal data breach, EduCCS communicated the incident to the supervisory authority with a document that outlined the reasons for the delay revealing that due to the lack of regular testing or modification, their incident response plan was not adequately prepared to handle such an attack.Based on this scenario, answer the following question:
Question:
Based on scenario 7, didEduCCS comply with GDPRregardingdata breach notification requirements?
- A. No, EduCCS should havereported the breach directly to affected clientsbefore informing the supervisory authority.
- B. Yes, EduCCS wasnot obligated to notifythe supervisory authority about the breach, since it occurred at itsIT service provider, X-Tech.
- C. Yes, EduCCS actedin compliancewith GDPR bynotifying the supervisory authority one week after the violation.
- D. No, EduCCS' notification to thesupervisory authorityafterone weekviolates GDPR's requirementfor timely notification.
Answer: D
Explanation:
UnderArticle 33(1) of GDPR, controllers mustreport a personal data breach to the supervisory authority within 72 hoursof becoming aware of it.EduCCS delayed notification beyond this timeframe, violating GDPR.
* Option A is correctbecauseEduCCS failed to notify the authority within 72 hours.
* Option B is incorrectbecauseEduCCS remains responsible for reporting the breach, even if it occurred atX-Tech.
* Option C is incorrectbecauseone-week delay violates GDPR's 72-hour requirement.
* Option D is incorrectbecausenotifying the supervisory authority is required first, unless the breach is unlikely to impact data subjects.
References:
* GDPR Article 33(1)(72-hour breach notification)
* Recital 85(Timely response to data breaches)
NEW QUESTION # 56
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