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PECB Certified Data Protection Officer Sample Questions (Q32-Q37):

NEW QUESTION # 32
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. Data processor, since they store COR Bank's data based on the purpose and conditions defined by COR Bank.
B. Joint controller with COR Bank, since they archive COR Bank's data and take technical decisions regarding data protection.
C. Data controller, since they control some of the data from the application processes of COR Bank.
D. Independent controller, since Tibko handles data security and storage.

Answer: A

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 # 33
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 Based on 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 theorganization'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:
Lisa implemented the updates to the data protection policy. Is she responsible for this under GDPR?

A. Yes, the DPO is responsible for implementing GDPR policies, procedures, and processes, as well as ensuring compliance.
B. No, the DPO is only responsible for proposing changes and obtaining evidence regarding specific GDPR requirements in the policy.
C. Yes, the DPO is responsible for all security-related tasks, including updating GDPR policies.
D. No, the DPO is responsible for monitoring compliance with GDPR butnotfor implementing the GDPR compliance policies.

Answer: D

Explanation:
UnderArticle 39(1)(b) of GDPR, theDPO's role is advisory-they monitor compliancebut donot actively implement policies.
* Option B is correctbecauseDPOs advise and monitor but do not execute policy updates.
* Option A is incorrectbecauseDPOs do more than just propose changes; they ensure compliance.
* Option C is incorrectbecause implementationis the responsibility of the controller, not the DPO.
* Option D is incorrectbecauseDPOs do not handle general security responsibilities.
References:
* GDPR Article 39(1)(b)(DPO's monitoring role)
* Recital 97(DPO's independence and advisory function)

NEW QUESTION # 34
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 holderof 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. This decision 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:
Based on scenario 1, MED shares patients' personal data with a health insurance company. Does MED comply with thepurpose limitation principle?

A. Yes, as long as the data is encrypted before sharing.
B. No, personal data should be collected for specified, explicit, and legitimate purposes in accordance with Article 5 of GDPR.
C. Yes, personal data may be used for purposes in the public interest or statistical purposes in accordance withArticle 89 of GDPR.
D. Yes, using personal data for creating health insurance plans is within the scope of the data collection purpose.

Answer: B

Explanation:
UnderArticle 5(1)(b) of GDPR, personal data must be collected for specific, explicit, and legitimate purposes and cannot be further processed in a manner incompatible with those purposes. Sharing medical data with an insurance company is a separate purpose and requires explicit consent or another lawful basis.
References:
* GDPR Article 5(1)(b)(Purpose limitation)

NEW QUESTION # 35
Scenario 8:MA store is an online clothing retailer founded in 2010. They provide quality products at a reasonable cost. One thing that differentiates MA store from other online shopping sites is their excellent customer service.
MA store follows a customer-centered business approach. They have created a user-friendly website with well-organized content that is accessible to everyone. Through innovative ideas and services, MA store offers a seamless user experience for visitors while also attracting new customers. When visiting the website, customers can filter their search results by price, size, customer reviews, and other features. One of MA store's strategies for providing, personalizing, and improving its products is data analytics. MA store tracks and analyzes the user actions on its website so it can create customized experience for visitors.
In order to understand their target audience, MA store analyzes shopping preferences of its customers based on their purchase history. The purchase history includes the product that was bought, shipping updates, and payment details. Clients' personal data and other information related to MA store products included in the purchase history are stored in separate databases. Personal information, such as clients' address or payment details, are encrypted using a public key. When analyzing the shopping preferences of customers, employees access only the information about the product while the identity of customers is removed from the data set and replaced with a common value, ensuring that customer identities are protected and cannot be retrieved.
Last year, MA store announced that they suffered a personal data breach where personal data of clients were leaked. The personal data breach was caused by an SQL injection attack which targeted MA store's web application. The SQL injection was successful since no parameterized queries were used.
Based on this scenario, answer the following question:
How could MA store prevent the SQL attack described in scenario 8?

A. Using security measures that support data protection at the database level, such as authorized queries
B. Processing only the data they actually need to achieve processing purposes in database and application servers
C. Using cryptographic protocols such as TLS as encryption mechanisms instead of a public key encryption

Answer: A

Explanation:
The SQL injection attack exploited vulnerabilities in the web application due to the lack of parameterized queries. GDPR mandates security measures under Article 32, which includes data integrity and confidentiality safeguards. Usingparameterized queries and prepared statementsat the database level would prevent attackers from injecting malicious SQL code. TLS encryption (option B) is crucial for secure communication but does not directly address SQL injection threats. Similarly, data minimization (option C) is a general best practice but does not provide specific protection against SQL injection.

NEW QUESTION # 36
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 are not eligible to request details on the collection, storage, or processing of their personal data.
B. No, data subjects can request access to how their data is being collected but not details about its processing or storage.
C. Yes, data subjects have theright to request detailson how their personal data is collected, stored, and processed.
D. No, because John's data was collected based on legitimate interest.

Answer: C

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 # 37
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Free PDF 2025 Authoritative PECB GDPR: PECB Certified Data Protection Officer Test Answers

PECB Certified Data Protection Officer Sample Questions (Q32-Q37):

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