IAPP CIPP-E Exam With Confidence Using Practice Dumps

The EDPB’s Guidelines 4/2019 on Article 25 Data Protection by Design and by Default provide guidance on how to implement the requirements of Article 25 of the GDPR, which obliges controllers to design and implement appropriate technical and organisational measures and necessary safeguards to ensure that the processing of personal data complies with the data protection principles and protects the rights and freedoms of data subjects. The guidelines also explain how to apply the concept of data protection by default, which means that by default, only personal data that are necessary for each specific purpose of the processing are processed.

The guidelines do not mention data ownership allocation as a practice that follows from the principles relating to the processing of personal data under EU data protection law. Data ownership allocation is not a concept that is recognised or defined by the GDPR or the EDPB. Data ownership allocation refers to the idea that data subjects or controllers have some form of property rights over the personal data that they provide or process. However, the GDPR does not grant such rights, but rather establishes a set of rules and obligations for the processing of personal data, based on the notion of accountability and responsibility of the controllers and processors. The GDPR also recognises the rights and freedoms of data subjects, such as the right of access, rectification, erasure, restriction, portability, objection and not to be subject to automated decision-making, which are not dependent on the ownership of the personal data, but on the fact that the personal data relate to them.

The other practices listed in the question, namely access control management, frequent pseudonymization key rotation and error propagation avoidance along the processing chain, are examples of practices that follow from the principles relating to the processing of personal data under EU data protection law, as explained in the guidelines. Access control management follows from the principle of integrity and confidentiality, which requires that personal data are processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. Frequent pseudonymization key rotation follows from the principle of data minimisation, which requires that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. Error propagation avoidance along the processing chain follows from the principle of accuracy, which requires that personal data are accurate and, where necessary, kept up to date.

References:

GDPR, Articles 5, 6, 7, 8, 9, 15, 16, 17, 18, 19, 20, 21, 22 and 25.

EDPB Guidelines 4/2019 on Article 25 Data Protection by Design and by Default, pages 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27 and 28.

 According to the UK GDPR, the processing of personal data must be lawful, fair and transparent1. Lawfulness means that there must be a valid legal basis for processing personal data, such as consent, contract, legal obligation, vital interests, public task or legitimate interests1. Fairness means that the processing must not be detrimental, unexpected or misleading to the individuals concerned1. Transparency means that the individuals must be informed about how their data is used, who it is shared with, what rights they have and how they can exercise them1. Therefore, the sentence that best summarizes these concepts is option A, which states that fairness and transparency refer to the communication of key information before collecting data; lawfulness refers to compliance with government regulations. References: 1

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