正確的なCIPP-Eテストトレーニング試験-試験の準備方法-一番優秀なCIPP-E資格認定試験

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CIPP-E資格認定試験 & CIPP-E参考書

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IAPP Certified Information Privacy Professional/Europe (CIPP/E) 認定 CIPP-E 試験問題 (Q280-Q285):

質問 # 280
SCENARIO
Please use the following to answer the next question:
Gentle Hedgehog Inc. is a privately owned website design agency incorporated in Italy. The company has numerous remote workers in different EU countries. Recently, the management of Gentle Hedgehog noticed a decrease in productivity of their sales team, especially among remote workers. As a result, the company plans to implement a robust but privacy-friendly remote surveillance system to prevent absenteeism, reward top performers, and ensure the best quality of customer service when sales people are interacting with customers.
Gentle Hedgehog eventually hires Sauron Eye Inc., a Chinese vendor of employee surveillance software whose European headquarters is in Germany. Sauron Eye's software provides powerful remote-monitoring capabilities, including 24/7 access to computer cameras and microphones, screen captures, emails, website history, and keystrokes. Any device can be remotely monitored from a central server that is securely installed at Gentle Hedgehog headquarters. The monitoring is invisible by default; however, a so-called Transparent Mode, which regularly and conspicuously notifies all users about the monitoring and its precise scope, also exists. Additionally, the monitored employees are required to use a built-in verification technology involving facial recognition each time they log in.
All monitoring data, including the facial recognition data, is securely stored in Microsoft Azure cloud servers operated by Sauron Eye, which are physically located in France.
What is the main problem with the 24/7 camera monitoring?

正解：A

解説：
The General Data Protection Regulation (GDPR) does not prohibit surveillance of employees in the workplace. Still, it requires employers to follow special rules to ensure that the rights and freedoms of employees are protected when processing their personal data. The GDPR applies to any processing of personal data in the context of the activities of an establishment of a controller or a processor in the EU, regardless of whether the processing takes place in the EU or not. The GDPR also applies to the processing of personal data of data subjects who are in the EU by a controller or processor not established in the EU, where the processing activities are related to the offering of goods or services to data subjects in the EU or the monitoring of their behaviour as far as their behaviour takes place within the EU.
The GDPR requires that any processing of personal data must be lawful, fair and transparent, and based on one of the six legal grounds specified in the regulation. The most relevant legal grounds for employee surveillance are the legitimate interests of the employer, the performance of a contract with the employee, or the compliance with a legal obligation. The GDPR also requires that any processing of personal data must be limited to what is necessary for the purposes for which they are processed, and that the data subjects must be informed of the purposes and the legal basis of the processing, as well as their rights and the safeguards in place to protect their data.
The GDPR also imposes specific obligations and restrictions on the processing of special categories of personal data, such as biometric data, which reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or which are processed for the purpose of uniquely identifying a natural person. The processing of such data is prohibited, unless one of the ten exceptions listed in the regulation applies. The most relevant exceptions for employee surveillance are the explicit consent of the data subject, the necessity for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law, or the necessity for reasons of substantial public interest.
The GDPR also sets out the rules and requirements for the transfer of personal data to third countries or international organisations, which do not ensure an adequate level of data protection. The transfer of such data is only allowed if the controller or processor has provided appropriate safeguards, such as binding corporate rules, standard contractual clauses, codes of conduct or certification mechanisms, and if the data subjects have enforceable rights and effective legal remedies.
Based on the scenario, the main problem with the 24/7 camera monitoring is that it has no valid legal basis to be implemented in the context of Gentle Hedgehog's business. This option is the most consistent with the GDPR's principles and requirements, as it:
Is not based on a valid legal ground for the processing of personal data, as it does not rely on the legitimate interests of the employer, the performance of a contract with the employee, or the compliance with a legal obligation. The legitimate interests of the employer to ensure the productivity, quality and security of the work performed by the employees must be balanced with the rights and freedoms of the employees, and the 24
/7 camera monitoring is likely to be disproportionate and intrusive, especially if it covers non-work-related activities and communications. The performance of a contract with the employee does not justify the 24/7 camera monitoring, as it is not necessary for the fulfilment of the contractual obligations of the employee or the employer. The compliance with a legal obligation does not apply to the 24/7 camera monitoring, as there is no specific law or regulation that requires such a measure in the context of Gentle Hedgehog's business.
Is not limited to what is necessary for the purposes of the monitoring, as it involves the collection and processing of excessive and irrelevant personal data, such as camera and microphone monitoring, which go beyond the scope of the work performed by the employees, and intrude into their private or personal sphere.
The 24/7 camera monitoring is also likely to capture personal data of third parties, such as customers, suppliers or visitors, whose consent is required for the monitoring, and whose rights and freedoms may be affected by the processing.
Is not transparent to the employees, as it does not inform them of the monitoring and its precise scope, and does not give them the opportunity to object or opt out of the monitoring. The monitoring is invisible by default, which means that the employees are not aware of when and how they are being monitored, and what personal data are being collected and processed. The so-called Transparent Mode, which regularly and conspicuously notifies all users about the monitoring and its precise scope, is also insufficient, as it does not provide the employees with a clear and comprehensive information notice, nor with a valid and specific consent form, as required by the GDPR.
Involves the processing of special categories of personal data, such as biometric data or data revealing political opinions or trade union membership, which are not necessary or proportionate for the purposes of the monitoring, and which do not fall under any of the exceptions listed in the regulation. The facial recognition technology used by the monitoring system is a form of biometric data processing, which is prohibited by the GDPR, unless the data subject has given explicit consent, or the processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law, or the processing is necessary for reasons of substantial public interest. None of these exceptions apply to the scenario, as the facial recognition technology is not used for any of these purposes, but rather for verifying the identity of the employees each time they log in. The camera and microphone monitoring may also capture personal data revealing political opinions or trade union membership, which are also special categories of personal data, and which are not relevant or proportionate for the purposes of the monitoring.
Involves the transfer of personal data to a third country, such as China, which does not provide an adequate level of data protection, and which may pose additional risks for the rights and freedoms of the employees.
The monitoring data, including the facial recognition data, are securely stored in Microsoft Azure cloud servers operated by Sauron Eye, which are physically located in France. However, Sauron Eye is a Chinese vendor of employee surveillance software, whose European headquarters is in Germany. This means that the monitoring data may be accessed or transferred by Sauron Eye to its parent company or other affiliates in China, which is a third country that does not ensure an adequate level of data protection, according to the European Commission. The transfer of personal data to China is only allowed if the controller or processor has provided appropriate safeguards, such as binding corporate rules, standard contractual clauses, codes of conduct or certification mechanisms, and if the data subjects have enforceable rights and effective legal remedies. However, the scenario does not indicate that any of these safeguards or remedies are in place, and therefore the transfer of personal data to China may violate the GDPR.
The other options listed in the question are not the main problem with the 24/7 camera monitoring, as they:
Are not directly related to the GDPR's principles and requirements, but rather to the national laws and regulations of the member states, which may vary depending on the specific context and circumstances of the monitoring. The GDPR does not specify a precise time limit for the operation of the camera monitoring, but leaves it to the national laws and regulations of the member states to determine the appropriate conditions and safeguards for the monitoring, taking into account the nature, scope, context and purposes of the processing, as well as the risks for the rights and freedoms of data subjects. The GDPR also does not require the approval of the trade union or the license from the national DPA for the camera monitoring, but leaves it to the national laws and regulations of the member states to establish the appropriate procedures and mechanisms for the consultation and involvement of the relevant stakeholders, such as the employees, the trade unions, the works councils, the DPAs or the courts.
Are not the main problem with the 24/7 camera monitoring, but rather the consequences or the implications of the main problem, which is the lack of a valid legal basis for the monitoring. The operation of the camera monitoring during non-business hours and employee holidays, or the accidental filming of third parties whose consent is required for the monitoring, are not the main problem, but rather the result of the main problem, which is the excessive and disproportionate collection and processing of personal data, which go beyond the scope of the work performed by the employees, and intrude into their private or personal sphere. The approval of the trade union or the license from the national DPA are not the main problem, but rather the potential solutions or remedies for the main problem, which is the absence of transparency and accountability for the monitoring, which do not inform the employees of the monitoring and its precise scope, and do not give them the opportunity to object or opt out of the monitoring.
References:
GDPR, Articles 5, 6, 7, 8, 9, 10, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 44, 45, 46, 47, 48, and 49.
EDPB Guidelines 3/2019 on processing of personal data through video devices, pages 5, 6, 7, 8, 9, 10, 11, 12,
13, and 14.
[EDPB Guidelines 07/2020 on the concepts of controller and processor in the GDPR]


質問 # 281
Once an organization has conducted an internal investigation to determine the scope of a ransomware attack, what is the appropriate next step in the process?

正解：D

解説：
The GDPR (General Data Protection Regulation) has strict data breach response requirements, particularly for ransomware attacks that affect personal data. The appropriate next step after an internal investigation is to assess the risks associated with the breach and notify affected parties if necessary.
Key GDPR Breach Response Steps (Article 33 & 34):
* Assess the risks to personal data
* If the breach poses a risk to individuals' rights and freedoms, the supervisory authority (DPA) must be notified within 72 hours.
* If there is a high risk, affected individuals must also be informed without undue delay.
* Why Answer Choice A is Correct
* Risk assessment is a critical first step after an internal investigation.
* If the breach meets the risk threshold, notification to authorities and individuals is required under GDPR.
* Why Other Answer Choices Are Incorrect:
* B (Notify Law Enforcement First): While law enforcement may be involved, GDPR does not mandate consulting law enforcement before conducting a risk assessment or notifying individuals.
* C (Informing the Public Immediately): Public disclosure via social media is not a GDPR requirement. Affected individuals and DPAs should be formally notified first.
* D (Waiting for Law Enforcement): GDPR does not allow waiting for law enforcement before fulfilling notification obligations. Controllers must act within 72 hours.
Conclusion: The correct next step after an internal investigation is to assess the risks and, if necessary, notify affected individuals and regulatory bodies as required under GDPR Articles 33 and 34.


質問 # 282
According to the European Data Protection Board, controllers responding to a data subject access request can refuse to provide a copy of personal data under certain conditions. Which of the following is NOT one of these conditions?

正解：C

解説：
The right of access is one of the fundamental rights of data subjects under the GDPR. It allows data subjects to obtain from the controller confirmation as to whether or not personal data concerning them are being processed, and, where that is the case, access to the personal data and certain information about the processing. The controller must provide a copy of the personal data undergoing processing to the data subject, unless the data subject requests otherwise. The right of access is not absolute and may be subject to limitations, restrictions or exceptions, in accordance with the GDPR and the national laws of the member states.
The EDPB has issued draft guidelines on the right of access, which provide more detailed guidance on how to handle data subject access requests and what are the possible grounds for refusing to provide a copy of the personal data. According to the draft guidelines, the controller can refuse to provide a copy of the personal data in the following situations:
If the data subject access request was sent to an employee that is not involved in the processing of such requests. In this case, the controller must inform the data subject of the appropriate contact point for submitting the request and must not consider the request as received until it reaches the designated person or unit. This does not mean that the controller can ignore or delay the request, but rather that the controller must ensure that the request is forwarded to the responsible person or unit as soon as possible.
If there is such a large amount of data that the controller cannot identify the data subject of the request. In this case, the controller can ask the data subject to provide additional information to enable the identification of the data subject, such as a unique identifier, a reference number, a specific time period, a location or a context of the processing. The controller must not ask for more information than is necessary and must not use the information for any other purpose than verifying the identity of the data subject.
If the personal data was processed in the past but is no longer at the controller's disposal at the time of the request. In this case, the controller must inform the data subject that the personal data are no longer available and explain the reasons why the personal data have been erased, anonymised, archived or otherwise disposed of. The controller must also provide the data subject with any relevant information about the retention period, the archiving policy, the anonymisation process or the disposal method of the personal data.
The controller cannot refuse to provide a copy of the personal data in the following situation:
If the controller is unable to use end-to-end encrypted emails for responding to such requests. In this case, the controller must still provide a copy of the personal data to the data subject, but must ensure that the communication is secure and that the personal data are protected from unauthorised or unlawful access, disclosure, alteration or destruction. The controller can use alternative means of communication, such as secure online platforms, password-protected files, encrypted devices or postal mail, depending on the preferences and circumstances of the data subject. The controller must also inform the data subject of the risks involved in the chosen communication method and obtain the data subject's consent before sending the personal data.
References:
GDPR, Articles 12, 13, 14, 15, 23 and 34.
EDPB Guidelines 01/2022 on data subject rights - Right of access Version 2, pages 6, 7, 8, 9, 10, 11, 12, 13,
14, 15 and 16.


質問 # 283
A data controller appoints a data protection officer. Which of the following conditions would NOT result in an infringement of Articles 37 to 39 of the GDPR?

正解：A

解説：
Reference: https://www.itgovernance.eu/fr-lu/data-protection-officer-dpo-under-the-gdpr-lu A data controller appointing a data protection officer who lacks ISO 27001 auditor certification would not result in an infringement of Articles 37 to 39 of the GDPR. According to Article 37 (5) of the GDPR, the data protection officer must bedesignated on the basis of professional qualities and, in particular, expert knowledge of data protection law and practices and the ability to fulfil the tasks referred to in Article 39 1. However, the GDPR does not specify any formal qualifications or certifications that the data protection officer must have, and leaves it to the discretion of the controller or the processor to determine the level of expertise required, depending on the complexity and sensitivity of the data processing activities 2. Therefore, the lack of ISO
27001 auditor certification, which is a standard for information security management systems, does not necessarily mean that the data protection officer is not qualified or competent for the role.
The other options are incorrect because they would result in an infringement of Articles 37 to 39 of the GDPR. According to Article 37 (6) of the GDPR, the data protection officer may be a staff member of the controller or the processor, or fulfil the tasks on the basis of a service contract 1. However, the data protection officer must be independent and report directly to the highest management level of the controller or theprocessor 3. Therefore, if the data protection officer is provided by the data processor, there may be a conflict of interest or a lack of autonomy, which would violate Article 38 (3) and (6) of the GDPR 4.
According to Article 38 (6) of the GDPR, the data protection officer may fulfil other tasks and duties, provided that they do not result in a conflict of interests 4. However, managing the marketing budget would likely involve a conflict of interests, as the data protection officer would have to oversee and advise on the data processing activities related to marketing, which may not be compatible with his or her role as a data protection officer 5. Therefore, if the data protection officer also manages the marketing budget, this would infringe Article 38 (6) of the GDPR 4.
According to Article 38 (3) of the GDPR, the data protection officer must not receive any instructions regarding the exercise of his or her tasks 4. The data protection officer must act in an independent manner and perform the tasks assigned by the GDPR, such as informing and advising the controller or the processor and the employees, monitoring compliance, cooperating with the supervisory authority, and acting as the contact point for data subjects and the supervisory authority 6. Therefore, if the data protection officer receives instructions from the data controller, this would infringe Article 38 (3) of the GDPR 4. References: 1: Article
37 of the GDPR 2: Guidelines on Data Protection Officers ('DPOs') 3: Article 38 (2) of the GDPR 4: Article
38 of the GDPR 5: Data protection officer (DPO) | European Commission 6: Article 39 of the GDPR


質問 # 284
SCENARIO
Please use the following to answer the next question:
WonderkKids provides an online booking service for childcare. Wonderkids is based in France, but hosts its website through a company in Switzerland. As part of their service, WonderKids will pass all personal data provided to them to the childcare provider booked through their system. The type of personal data collected on the website includes the name of the person booking the childcare, address and contact details, as well as information about the children to be cared for including name, age, gender and health information. The privacy statement on Wonderkids' website states the following:
"WonderkKids provides the information you disclose to us through this website to your childcare provider for scheduling and health and safety reasons. We may also use your and your child's personal information for our own legitimate business purposes and we employ a third-party website hosting company located in Switzerland to store the dat a. Any data stored on equipment located in Switzerland meets the European Commission provisions for guaranteeing adequate safeguards for you and your child's personal information. We will only share you and your child's personal information with businesses that we see as adding real value to you. By providing us with any personal data, you consent to its transfer to affiliated businesses and to send you promotional offers."
"We may retain you and your child's personal information for no more than 28 days, at which point the data will be depersonalized, unless your personal information is being used for a legitimate business purpose beyond 28 days where it may be retained for up to 2 years."
"We are processing you and your child's personal information with your consent. If you choose not to provide certain information to us, you may not be able to use our services. You have the right to: request access to you and your child's personal information; rectify or erase you or your child's personal information; the right to correction or erasure of you and/or your child's personal information; object to any processing of you and your child's personal information. You also have the right to complain to the supervisory authority about our data processing activities." What must the contract between WonderKids and the hosting service provider contain?

正解：D


質問 # 285
......

Fast2testは、精巧にまとめられた非常に効率的な最高の有効なCIPP-E試験問題を提供するWebサイトです。CIPP-E学習ガイドで学習すると、時間と労力を節約できます。物事以外のいくつか。 CIPP-Eトレーニング資料の合格率とヒット率も非常に高く、数千人の候補者が当社のWebサイトを信頼し、CIPP-E試験に合格しています。候補者には非常に多くの保証を提供しており、CIPP-E学習教材を心配なく購入できます。

CIPP-E資格認定試験: https://jp.fast2test.com/CIPP-E-premium-file.html

IAPP CIPP-Eテストトレーニング さらに、適切な学習ツールも同様に重要です、当社Fast2testのCIPP-E学習教材は常に高い合格率を維持していることがわかっています、CIPP-E試験のブレーンダンプは、より大きな会社に注目させる能力を証明できます、それはFast2testのIAPPのCIPP-E試験の問題と解答を含まれます、IAPP CIPP-Eテストトレーニング 我々の社員は全日中で客様のお問い合わせをお待ちしております、我々は多くの受験生にIAPPのCIPP-E試験に合格させたことに自慢したことがないのです、彼らはFast2test CIPP-E 資格認定試験の問題集が有効なこと確認しました。

正直内容は単純だけど、作品としては楽しいよ、あっという間だったよ 淡々とした口調だった、さらに、適切な学習ツールも同様に重要です、当社Fast2testのCIPP-E学習教材は常に高い合格率を維持していることがわかっています。

正確的なCIPP-Eテストトレーニング & 合格スムーズCIPP-E資格認定試験 | 大人気CIPP-E参考書

CIPP-E試験のブレーンダンプは、より大きな会社に注目させる能力を証明できます、それはFast2testのIAPPのCIPP-E試験の問題と解答を含まれます、我々の社員は全日中で客様のお問い合わせをお待ちしております。

P.S. Fast2testがGoogle Driveで共有している無料かつ新しいCIPP-Eダンプ：https://drive.google.com/open?id=1U3Obd5VUB4as2bDwh6SS-dNTRjkF8WWR

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