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PECB GDPR Exam Syllabus Topics:
Topic
Details
Topic 1
- Roles and responsibilities of accountable parties for GDPR compliance: This section of the exam measures the skills of Compliance Managers and covers the responsibilities of various stakeholders, such as data controllers, data processors, and supervisory authorities, in ensuring GDPR compliance. It assesses knowledge of accountability frameworks, documentation requirements, and reporting obligations necessary to maintain compliance with regulatory standards.
Topic 2
- Technical and organizational measures for data protection: This section of the exam measures the skills of IT Security Specialists and covers the implementation of technical and organizational safeguards to protect personal data. It evaluates the ability to apply encryption, pseudonymization, and access controls, as well as the establishment of security policies, risk assessments, and incident response plans to enhance data protection and mitigate risks.
Topic 3
- Data protection concepts: General Data Protection Regulation (GDPR), and compliance measures
Topic 4
- This section of the exam measures the skills of Data Protection Officers and covers fundamental concepts of data protection, key principles of GDPR, and the legal framework governing data privacy. It evaluates the understanding of compliance measures required to meet regulatory standards, including data processing principles, consent management, and individuals' rights under GDPR.
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PECB Certified Data Protection Officer Sample Questions (Q46-Q51):
NEW QUESTION # 46
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 transported daily. 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 bedisplayed. 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:
Is aDPIA necessaryfor Bus Spot?
- A. Yes, because the installation of aCCTV systemin Bus Spot's buses involvessystematic monitoring of a large number of individuals.
- B. Yes, because the installation of a CCTV system in Bus Spot's buses involves asystematic and extensive evaluation of personal aspectsrelating to natural personsbased on automated processing.
- C. No, because the installation of a CCTV system in Bus Spot's buses doesnot involveprocessing of data that is likely to result in a high risk to the rights and freedoms of data subjects.
- D. No, because CCTV cameras used for security reasons are automaticallyexemptfrom GDPR requirements.
Answer: A
Explanation:
UnderArticle 35(3)(c) of GDPR, a DPIA is requiredwhen a large-scale systematic monitoring of public spaces is conducted. CCTV cameras inpublic transportation capture many individuals, making a DPIA mandatory.
* Option A is correctbecauseCCTV monitoring in public spaces is considered high-risk processing.
* Option B is incorrectbecause CCTV processingdoes not involve automated decision-making or profiling.
* Option C is incorrectbecauseCCTV processing affects a large number of individuals, posing potential risks.
* Option D is incorrectbecausesecurity cameras are subject to GDPR unless used for purely household purposes (Recital 18).
References:
* GDPR Article 35(3)(c)(DPIA requirement for systematic monitoring)
* Recital 91(Use of DPIA in video surveillance)
NEW QUESTION # 47
Question:
What is therole of the DPO in a DPIA?
- A. Approvethe DPIA and ensure all risks are eliminated.
- B. Conductthe DPIA.
- C. Recordthe DPIA outcomes.
- D. Determineif a DPIA is necessary.
Answer: D
Explanation:
UnderArticle 39(1)(c) of GDPR, theDPO advises on the necessity of conducting a DPIAbut doesnot conduct it themselves. Thecontroller is responsiblefor carrying out the DPIA.
* Option B is correctbecausethe DPO must determine whether a DPIA is required and provide recommendations.
* Option A is incorrectbecauseconducting the DPIA is the responsibility of the controller, not the DPO.
* Option C is incorrectbecausewhile the DPO can assist, DPIA documentation is the controller's duty.
* Option D is incorrectbecauseDPOs advise but do not approve or eliminate all risks-risk management remains the responsibility of the controller.
References:
* GDPR Article 39(1)(c)(DPO advises on DPIA necessity)
* Recital 97(DPOs provide oversight, not execution)
NEW QUESTION # 48
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:
Scenario:
Soyled's customers are required to provide theirbank account detailsto buy a product. According to the GDPR, is this data processing lawful?
- A. No, because financial information cannot be collected without explicit consent.
- B. Yes, because the processing is necessary for the fulfillment of the purchase agreement.
- C. No, sensitive data, such as bank account details, should only be processed by official authorities.
- D. Yes, because Soyled has a privacy policy in place that ensures the protection of personal data.
Answer: B
Explanation:
UnderArticle 6(1)(b) of GDPR, processing is lawfulif it is necessary for the performance of a contract with the data subject. Since the customers must provide bank details to complete their purchases, this processing isnecessaryfor fulfilling the agreement.
* Option A is correctbecause payment data is essential for transaction processing, which aligns with GDPR's contract basis.
* Option B is incorrectbecause having a privacy policy does not automatically justify data processing.
* Option C is incorrectbecause financial data can be processed byauthorized commercial entitiesunder GDPR.
* Option D is incorrectbecauseexplicit consent is not requiredwhen processing is contractually necessary.
References:
* GDPR Article 6(1)(b)(Processing necessary for contract performance)
* Recital 44(Necessity of processing for contract fulfillment)
NEW QUESTION # 49
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:
According to scenario 8, by storing clients' information in separate databases, MA store used a:
- A. Data protection by design strategy
- B. Pseudonymization method
- C. Data protection by default technology
Answer: A
Explanation:
Separating databases for different types of data aligns with the principle ofData Protection by Design and by Defaultunder Article 25 of GDPR. By structuring data storage in a way that limits access and minimizes exposure, MA Store is proactively implementing security measures that prevent unauthorized access and mitigate risks in case of a breach. This approach supports theconfidentiality, integrity, and availabilityof personal data as required by GDPR.
NEW QUESTION # 50
Scenario 9:Soin is a French travel agency with the largest network of professional travel agents throughout Europe. They aim to create unique vacations for clients regardless of the destinations they seek. The company specializes in helping people find plane tickets, reservations at hotels, cruises, and other activities.
As any other industry, travel is no exception when it comes to GDPR compliance. Soin was directly affected by the enforcement of GDPR since its main activities require the collection and processing of customers' data.
Data collected by Soin includes customer's ID or passport details, financial and payment information, and contact information. This type of data is defined as personal by the GDPR; hence, Soin's data processing activities are built based on customer's consent.
At the beginning, as for many other companies, GDPR compliance was a complicated issue for Soin.
However, the process was completed within a few months and later on the company appointed a DPO. Last year, the supervisory authority of France, requested the conduct of a data protection external audit in Soin without an early notice. To ensure GDPR compliance before an external audit was conducted, Soin organized an internal audit. The data protection internal audit was conducted by the DPO of the company. The audit was initiated by firstly confirming the accuracy of records related to all current Soin's data processing activities.
The DPO considered that verifying compliance to Article 30 of GDPR would help in defining the data protection internal audit scope. The DPO noticed that not all processing activities of Soin were documented as required by the GDPR. For example, processing activities records of the company did not include a description of transfers of personal data to third countries. In addition, there was no clear description of categories of personal data processed by the company. Other areas that were audited included content of data protection policy, data retention guidelines, how sensitive data is stored, and security policies and practices.
The DPO conducted interviews with some employees at different levels of the company. During the audit, the DPO came across some emails sent by Soin's clients claiming that they do not have access in their personal data stored by Soin. Soin's Customer Service Department answered the emails saying that, based on Soin's policies, a client cannot have access to personal data stored by the company. Based on the information gathered, the DPO concluded that there was a lack of employee awareness on the GDPR.
All these findings were documented in the audit report. Once the audit was completed, the DPO drafted action plans to resolve the nonconformities found. Firstly, the DPO created a new procedure which could ensure the right of access to clients. All employees were provided with GDPR compliance awareness sessions.
Moreover, the DPO established a document which described the transfer of personal data to third countries and the applicability of safeguards when this transfer is done to an international organization.
Based on this scenario, answer the following question:
Can the DPO appointed by Soin carry out the data protection external audit requested by the supervisory authority?
- A. Yes, data protection external audits should be conducted by auditors contracted by Soin who can be employees of the company
- B. Yes, Soin's DPO is allowed to conduct a data protection external audit but only if requested by the supervisory authority
- C. No, data protection external audits should be conducted by independent auditors who are not part of the company being audited
Answer: C
Explanation:
GDPR Article 58(1) gives supervisory authorities the power to conduct external audits, which mustbe independent and unbiased. A company's internal DPO cannot conduct an external audit, as this would pose a conflict of interest (Recital 97). External audits should be conducted by supervisory authorities or third-party auditors, ensuring objectivity.
NEW QUESTION # 51
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