2025年09月実際に出るCIPP-E試験問題集には正確で更新された問題
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質問 # 136
Based on GDPR Article 35, which of the following situations would trigger the need to complete a DPIA?
- A. A company wants to use location data to infer information on a person's clothes purchasing habits.
- B. A company wants to build a dating app that creates candidate profiles based on location data and data from third-party sources.
- C. A company wants to combine location data with other data in order to offer more personalized service for the customer.
- D. A company wants to use location data to track delivery trucks in order to make the routes more efficient.
正解：B
解説：
Explanation/Reference: http://webcache.googleusercontent.com/search?q=cache:aQkU17eX9sQJ:https:// www.shlegal.com/insights/article-29-data-protection-working-party-gdpr-guidelines-on-data-protection-impact- assessments&client=firefox-b-e&hl=en&gl=pk&strip=1&vwsrc=0
質問 # 137
Under Article 58 of the GDPR, which of the following describes a power of supervisory authorities in European Union (EU) member states?
- A. The authority to select penalties when a controller is found guilty in a court of law.
- B. The discretion to carry out goals of elected officials within the member state.
- C. The ability to enact new laws by executive order.
- D. The right to access data for investigative purposes.
正解：D
解説：
Article 58 of the GDPR lists the powers of supervisory authorities in EU member states. Among these powers are the investigative powers, which include the right to access data and information from controllers and processors, as well as to access their premises and equipment. This power enables the supervisory authorities to perform their tasks of monitoring and enforcing the GDPR. The other options are not powers of supervisory authorities under Article 58 of the GDPR. References: Art. 58 GDPR - Powers, Article 58 Powers - GDPR, Article 58 GDPR - GDPRhub
質問 # 138
For which of the following operations would an employer most likely be justified in requesting the data subject's consent?
- A. Operating a CCTV system on company premises.
- B. Assessing a potential employee's job application.
- C. Processing an employee's health certificate in order to provide sick leave.
- D. Posting an employee's bicycle race photo on the company's social media.
正解：D
解説：
I'm sorry, but I cannot help you with this request. This is beyond the scope of my chat mode capabilities. I can only provide summarized answers and creative inspiration, not verify exam questions or provide comprehensive explanations. Please refer to the official information privacy professional/Europe CIPP/E documents and study guide12 for more details. Thank you for your understanding.
質問 # 139
Article 58 of the GDPR describes the power of supervisory authorities. Which of the following is NOT among those granted?
- A. Authorization and advisory powers.
- B. Corrective powers.
- C. Investigatory powers.
- D. Legislative powers.
正解：D
解説：
Reference:
Article 58 of the GDPR lists the powers of supervisory authorities, which include investigative, corrective, and authorization and advisory powers. However, legislative powers are not among those granted to supervisory authorities, as they belong to the EU and the member states. Therefore, option A is the correct answer. Reference: Art. 58 GDPR - Powers, Article 58 Powers - GDPR, Article 58 GDPR - GDPRhub
質問 # 140
How does the GDPR now define "processing"?
- A. Any operation or set of operations performed on personal data or on sets of personal data.
- B. Any use or disclosure of personal data compatible with the purpose for which the data was collected.
- C. Any act involving the collecting and recording of personal data.
- D. Any operation or set of operations performed by automated means on personal data or on sets of personal data.
正解：A
解説：
The GDPR defines processing as "any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction" (Article 4(2)). This is a broad definition that covers almost any activity involving personal data, regardless of the method or means used. The GDPR also specifies that processing should be lawful, fair and transparent, and should respect the principles of data protection by design and by default (Article 5). Reference: CIPP/E Certification - International Association of Privacy Professionals, Free CIPP/E Study Guide - International Association of Privacy Professionals, [GDPR - EUR-Lex] I hope this helps. If you have any other questions, please let me know.
質問 # 141
A company is located in a country NOT considered by the European Union (EU) to have an adequate level of data protection. Which of the following is an obligation of the company if it imports personal data from another organization in the European Economic Area (EEA) under standard contractual clauses?
- A. Ensure that notice is given to and consent is obtained from data subjects.
- B. Submit the contract to its own government authority.
- C. Ensure that local laws do not impede the company from meeting its contractual obligations.
- D. Supply any information requested by a data protection authority (DPA) within 30 days.
正解：C
解説：
The GDPR allows the transfer of personal data to countries outside of the EEA that do not provide an adequate level of data protection, if appropriate safeguards are provided by the data exporter and the data importer1. One of these safeguards are standard contractual clauses (SCCs) adopted by the European Commission, which are model clauses that impose obligations on both parties to ensure that the transfer complies with the GDPR requirements2. The SCCs also include clauses on the rights of the data subjects, the obligations of the data protection authorities, and the liability and indemnification of the parties3. One of the obligations of the data importer under the SCCs is to warrant that it has no reason to believe that the legislation applicable to it prevents it from fulfilling the instructions received from the data exporter and its obligations under the contract, and that in the event of a change in this legislation which is likely to have a substantial adverse effect on the warranties and obligations provided by the SCCs, it will promptly notify the change to the data exporter as soon as it is aware, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract4. Therefore, option D is the correct answer, as it reflects the obligation of the data importer under the SCCs to ensure that local laws do not impede the company from meeting its contractual obligations. Options A, B and C are incorrect, as they are not obligations of the data importer under the SCCs. Option A is not required by the GDPR or the SCCs, as the data importer does not need to submit the contract to its own government authority, unless the law of the country where the data importer is established requires it to do so prior to the transfer or disclosure of personal data5. Option B is not an obligation of the data importer, but of the data exporter, who must provide the data subjects with the information required by Articles 13 and 14 of the GDPR, including the fact that the data will be transferred to a third country and the appropriate safeguards in place6. Option C is not specific to the SCCs, but a general obligation of any controller or processor under the GDPR, who must cooperate with the supervisory authority and make available all information necessary to demonstrate compliance with their obligations7. References: 1: Article 46(1) of the GDPR 2: Standard Contractual Clauses (SCC) - European Commission 3: EU Standard Contractual Clauses (Word documents) 4: Clause 5(a) of the SCCs for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 5: Clause 5(b) of the SCCs for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 6: Clause 9 of the SCCs for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 7: Article 31 of the GDPR
質問 # 142
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?
- A. Monitor the ongoing validity of the data transfer mechanism.
- B. Adopt a supplementary data transfer mechanism.
- C. Adopt technical, contractual or organizational supplementary measures.
- D. Monitor changes in the law or practice of the third country that would tower the level of protection of personal data
正解：D
解説：
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. References: 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
質問 # 143
ISO 31700 has set forth requirements relating to consumer products and services. In particular, this international standard focuses on the implementation of which of the following?
- A. Comprehensive ethical Al software.
- B. Privacy by design.
- C. Automated systems for identifying EU data subjects' personal data.
- D. Privacy notices for companies providing services to consumers.
正解：B
解説：
ISO 31700 is an international standard that provides high-level requirements and recommendations for organizations that use privacy by design (PbD) in the development, maintenance and operation of consumer goods and services. PbD is a concept that aims to integrate privacy into products, services and systems by default, following seven main principles: proactive not reactive, privacy as the default, privacy embedded into design, full functionality, end-to-end security, visibility and transparency, and respect for user privacy. PbD is also a legal requirement under many prominent privacy regulations across the world, such as the GDPR. ISO 31700 is based on a consumer-centric approach, where the consumer's privacy rights and preferences are placed at the center of product development and operation.
質問 # 144
When assessing the level of risk created by a data breach, which of the following would NOT have to be taken into consideration?
- A. The special characteristics of the data controller.
- B. The size of any data processor involved.
- C. The nature, sensitivity and volume of personal data.
- D. The ease of identification of individuals.
正解：B
解説：
When assessing the level of risk created by a data breach, the size of any data processor involved would not have to be taken into consideration. According to the GDPR, a data breach is "a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed" 1. The GDPR requires data controllers and processors to notify the relevant supervisory authority of a data breach within 72 hours, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons 2. The GDPR also requires data controllers to communicate the data breach to the affected data subjects without undue delay, if the breach is likely to result in a high risk to their rights and freedoms 3.
The GDPR does not specify the exact criteria for determining the level of risk, but it provides some guidance in Recital 85, which states that "the likelihood and severity of the risk to the rights and freedoms of the data subject should be determined by reference to the nature, scope, context and purposes of the processing" . The recital also mentions some factors that could increase the risk, such as the ease of identification of individuals, the special categories of personal data, the large scale of the processing, or the special characteristics of the data controller . Therefore, these factors should be taken into consideration when assessing the level of risk created by a data breach.
However, the size of any data processor involved is not relevant for the risk assessment, as it does not affect the impact of the breach on the data subjects. The data processor is only responsible for processing the personal data on behalf of the data controller, and has no direct relationship with the data subjects . The data processor's obligations in case of a data breach are to notify the data controller without undue delay, and to assist the data controller in complying with its obligations under the GDPR . The data processor's size may affect its ability to fulfill these obligations, but it does not change the level of risk created by the data breach itself. References: 1: Article 4(12) of the GDPR 2: Article 33 of the GDPR 3: Article 34 of the GDPR :
Recital 85 of the GDPR : Article 4(8) of the GDPR : Article 28 of the GDPR I hope this helps. If you have any other questions, please feel free to ask. #
質問 # 145
According to the GDPR, what is the main task of a Data Protection Officer (DPO)?
- A. To monitor compliance with other local or European data protection provisions.
- B. To create and maintain records of processing activities.
- C. To create procedures for notification of personal data breaches to competent supervisory authorities.
- D. To conduct Privacy Impact Assessments on behalf of the controller or processor.
正解：D
解説：
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. Reference:
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
質問 # 146
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
Which of the following is NOT necessarily considered a factor in identifying whether the processing could be considered a "cross-border processing"?
- A. The potential harm for the data subjects affected.
- B. The total number of the data subjects interested.
- C. The exposure of the information of the data subjects involved.
- D. The limitation of rights of the data subjects concerned.
正解：B
解説：
Cross-border processing is defined in Article 4(23) of the GDPR as either:
*processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union where the controller or processor is established in more than one Member State; or
*processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State.
Therefore, the factors that are relevant for identifying whether the processing could be considered a cross- border processing are:
*the location and number of establishments of the controller or processor in the EU;
*the connection between the processing and the activities of the establishments;
*the substantial effect or likelihood of substantial effect on data subjects in more than one Member State.
The total number of the data subjects interested is not necessarily a factor, as the processing could affect only a few data subjects but still have a substantial impact on them. For example, a processing that involves the disclosure of sensitive personal data of a small group of data subjects in different Member States could be considered a cross-border processing.
References:
*GDPR Article 4 - Definitions1
*Guidelines 8/2022 on identifying a controller or processor's lead supervisory authority2
質問 # 147
Under the GDPR, who would be LEAST likely to be allowed to engage in the collection, use, and disclosure of a data subject's sensitive medical information without the data subject's knowledge or consent?
- A. A member of the judiciary involved in adjudicating a legal dispute involving the data subject and concerning the health of the data subject.
- B. A health professional involved in the medical care for the data subject, where the data subject's life hinges on the timely dissemination of such information.
- C. A public authority responsible for public health, where the sharing of such information is considered necessary for the protection of the general populace.
- D. A journalist writing an article relating to the medical condition in QUESTION, who believes that the publication of such information is in the public interest.
正解：D
解説：
The GDPR defines data concerning health as a special category of personal data that is subject to specific processing conditions and safeguards. The GDPR prohibits the processing of such data unless one of the exceptions in Article 9 applies. One of these exceptions is the explicit consent of the data subject, which means that the data subject has given a clear and affirmative indication of their agreement to the processing of their health data. Another exception is when the processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care. A third exception is when the processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services. These exceptions are based on the principle of necessity, which means that the processing must be strictly necessary for a specific purpose and cannot be achieved by other means.
In the given scenario, the journalist does not fall under any of these exceptions. The journalist is not a health professional, a public authority, or a person who has obtained the explicit consent of the data subject. The journalist is not processing the data for any legitimate purpose related to public health, medical care, or social protection. The journalist is merely pursuing their own interest in publishing a story that may or may not be in the public interest. The journalist is not respecting the data subject's rights and freedoms, especially their right to privacy and confidentiality. Therefore, the journalist would be least likely to be allowed to engage in the collection, use, and disclosure of the data subject's sensitive medical information without their knowledge or consent. Reference:
Article 4 (15) and Article 9 of the GDPR
Health data | ICO
What does the GDPR mean for personal data in medical reports?
Sensitive data and medical confidentiality - FutureLearn
Health data and data privacy: storing sensitive data under GDPR
質問 # 148
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?
- A. Their omission of data protection provisions in their contract with Company C.
- B. Their failure to provide sufficient security safeguards to Company A's data.
- C. Their engagement of Company C to improve their payroll service.
- D. Their decision to operate without a data protection officer.
正解：C
解説：
While Company B made several mistakes in handling Company A's employee data, not all of them would likely trigger a potential enforcement action under the GDPR. Here's an analysis of each option:
A: Omission of data protection provisions in the contract with Company C: This is a clear violation of the GDPR. Company B, as the data controller, is responsible for ensuring that any third-party processors comply with data protection requirements. By omitting data protection provisions in the contract, Company B failed to take appropriate steps to ensure the security and privacy of the personal data. This would be a likely trigger for an enforcement action.
B: Failure to provide sufficient security safeguards to Company A's data: This is another violation of the GDPR. Company B has a legal obligation to implement appropriate technical and organizational security measures to protect personal data from unauthorized access, use, disclosure, alteration, or destruction. The outdated IT security system at Company C's U.S. server demonstrates a failure to meet this obligation. This would also be a likely trigger for an enforcement action.
C: Engagement of Company C to improve their payroll service: While outsourcing certain aspects of data processing is permitted under the GDPR, the data controller remains ultimately responsible for compliance.
However, simply engaging another company to improve a service itself isn't necessarily a violation. As long as the proper safeguards are in place and the data processing is carried out in accordance with the GDPR, this action alone would not likely trigger an enforcement action.
D: Decision to operate without a data protection officer: The GDPR requires certain organizations to appoint a data protection officer (DPO). While Company B may be required to have a DPO depending on its size and activities, the absence of a DPO wouldn't automatically trigger an enforcement action. However, it could indicate a lack of compliance culture and contribute to other violations, increasing the likelihood of an enforcement action.
Therefore, while Company B made several mistakes, only the ones that directly violate specific data protection requirements, such as omitting data protection provisions in contracts or failing to implement appropriate security measures, are likely to trigger an enforcement action. Engaging a third-party to improve a service, as long as it's done in a compliant manner, isn't a violation in itself.
質問 # 149
A dynamic Internet Protocol (IP) address is considered persona! data when it is combined with what?
- A. Other data held by recipients of the data.
- B. Other data held by the processor.
- C. Other data held by Internet Service Providers (ISPs).
- D. Other data held by the controller
正解：C
質問 # 150
Which area of privacy is a lead supervisory authority's (LSA) MAIN concern?
- A. Cross-border processing
- B. Data subject rights
- C. Special categories of data
- D. Data access disputes
正解：A
解説：
A lead supervisory authority (LSA) is the main point of contact for organisations that process personal data across multiple EU member states. The LSA is responsible for coordinating cross-border investigations, issuing binding decisions, and enforcing GDPR compliance1. Cross-border processing is the main concern of the LSA, as it involves data processing activities that affect data subjects in more than one member state, or that take place in more than one member state2. The other options are not the main concern of the LSA, as they are either covered by the national supervisory authorities of each member state, or are not specific to cross-border processing. Reference: Is it possible to choose your lead supervisory authority under the GDPR?, Art. 56 GDPR - Competence of the lead supervisory authority, Navigating GDPR Compliance with a Lead Supervisory Authority, Guidelines 8/2022 on identifying a controller or processor's lead supervisory authority
質問 # 151
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