GDPR試験正確な問題集、学習ノートと理論 [2025年06月]
100%高得点合格保証GDPR無制限84解答
PECB GDPR 認定試験の出題範囲：
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質問 # 29
Scenario4:
Berc is a pharmaceutical company headquartered in Paris, France, known for developing inexpensive improved healthcare products. They want to expand to developing life-saving treatments. Berc has been engaged in many medical researches and clinical trials over the years. These projects required the processing of large amounts of data, including personal information. Since 2019, Berc has pursued GDPR compliance to regulate data processing activities and ensure data protection. Berc aims to positively impact human health through the use of technology and the power of collaboration. They recently have created an innovative solution in participation with Unty, a pharmaceutical company located in Switzerland. They want to enable patients to identify signs of strokes or other health-related issues themselves. They wanted to create a medical wrist device that continuously monitors patients' heart rate and notifies them about irregular heartbeats. The first step of the project was to collect information from individuals aged between 50 and 65. The purpose and means of processing were determined by both companies. The information collected included age, sex, ethnicity, medical history, and current medical status. Other information included names, dates of birth, and contact details. However, the individuals, who were mostly Berc's and Unty's customers, were not aware that there was an arrangement between Berc and Unty and that both companies have access to their personal data and share it between them. Berc outsourced the marketing of their new product to an international marketing company located in a country that had not adopted the adequacy decision from the EU commission. However, since they offered a good marketing campaign, following the DPO's advice, Berc contracted it. The marketing campaign included advertisement through telephone, emails, and social media. Berc requested that Berc's and Unty's clients be first informed about the product. They shared the contact details of clients with the marketing company.Based on this scenario, answer the following question:
Question:
Based on scenario 4, Bercshared personal information of its clients with an international marketing companyeven thoughan adequacy decision was absent. Which of the following is avalid reasonto do so?
- A. Thecontroller or processor provides appropriate safeguardsfor data protection.
- B. The transfer of data does not depend on the adoption of an adequacy decision by the country where the company is located.
- C. Authorization for data transfer from Berc'sChief Information Security Officer (CISO)is obtained.
- D. The marketing company's reputation ensures compliance with data protection standards.
正解：A
解説：
UnderArticle 46 of GDPR, in theabsence of an adequacy decision, controllers can transfer dataonly if appropriate safeguards(e.g., Standard Contractual Clauses, Binding Corporate Rules) are in place.
* Option C is correctbecausesafeguards such as SCCsallow data transfers when no adequacy decision exists.
* Option A is incorrectbecauseadequacy decisions are a legal requirement, not optional.
* Option B is incorrectbecausea CISO cannot authorize GDPR data transfers.
* Option D is incorrectbecausereputation does not ensure GDPR compliance.
References:
* GDPR Article 46(1)(Appropriate safeguards for data transfers)
* Recital 108(Legally binding commitments for data protection)
質問 # 30
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:
The GDPR indicates that the processing of personal data should be based on alegal contractwith the data subject. Based on scenario 6, has Soyled fulfilled this requirement?
- A. Yes, once the account is created, Soyled informs its customers that their personal data will be shared with the network.
- B. Yes, data subjects are informed about the purpose of collecting the email address and phone number before the data is collected.
- C. No, data subjects are informed that the personal data will be shared with Soyled's networkonly afterthe personal data is collected.
- D. No, because Soyled did not obtain explicit consent for data processing.
正解：C
解説：
UnderArticle 6(1) of GDPR, processing personal data must have alawful basis, such as consent, contract, legal obligation, or legitimate interest. Additionally, underArticle 13, controllers must inform usersbefore collecting their data.
Soyledfailed to disclosethat personal data would be shared with the networkbefore collection, whichviolates GDPR transparency requirements.Option C is correct.Option Ais incorrect because informing about email collection does not mean lawful processing.Option Bis incorrect because the information was not disclosed at the right time.Option Dis incorrect because explicit consent is not necessarily required if another lawful basis applies.
References:
* GDPR Article 6(1)(Lawfulness of processing)
* GDPR Article 13(1)(Transparency in data processing)
質問 # 31
When pseudonymization is used in a dataset, the data is divided into restricted access data and non- identifiable data. This restricted access data includes gender, occupation, and age, whereas the non- identifiable data includes only nationality. Is this correct?
- A. Yes, when pseudonymization is used, non-identifiable data includes only nationality, whereas restricted access data includes gender, occupation, and age
- B. No, only anonymization can be used to divide a dataset into restricted access data and non-identifiable data
- C. No, non-identifiable data includes gender, nationality, and occupation, whereas restricted access data includes first name, last name, and age, among others
正解：C
解説：
Pseudonymization does not remove data identifiability but rather reduces the direct link to anindividual (GDPR Article 4(5)). Non-identifiable data includes attributes like gender and occupation, whereas restricted access data includes directly identifying details such as names. Anonymization, not pseudonymization, ensures complete irreversibility.
質問 # 32
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. Processing only the data they actually need to achieve processing purposes in database and application servers
- B. Using security measures that support data protection at the database level, such as authorized queries
- C. Using cryptographic protocols such as TLS as encryption mechanisms instead of a public key encryption
正解：B
解説：
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.
質問 # 33
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 holder of 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:
If a patient requests MED to permanently erase their data, MED should:
- A. Refuse the request because medical data must be retained indefinitely for future reference.
- B. Erase the personal data only if required to comply with a legal obligation.
- C. Reject the request since the medical history of patients cannot be permanently erased.
- D. Erase the personal data if it is no longer needed for its original purpose.
正解：D
解説：
Under Article 17 of theGeneral Data Protection Regulation (GDPR), also known as the "Right to be Forgotten," data subjects have the right to request the erasure of their personal data when:
* The data is no longer necessary for the purpose for which it was collected.
* The data subject withdraws consent (where processing was based on consent).
* The data was processed unlawfully.
In this scenario, if the data is no longer necessary for the original purpose (e.g., if the patient has completed their treatment and there are no legal retention obligations), MED should erase the data. However, there are exceptions under GDPR, such as legal retention requirements for medical records under national healthcare regulations.
Rejecting the request outright (Option A) is incorrect because GDPR requires controllers to assess whether retention is still necessary. Similarly,Option Cis too restrictive because GDPR allows deletion even if no legal obligation mandates it.Option Dis incorrect because indefinite retention is not permitted unless a valid justification exists.
References:
* GDPR Article 17(Right to Erasure)
* Recital 65(Clarification on when personal data can be erased)
* Article 5(1)(e)(Storage limitation principle)
質問 # 34
Scenario5:
Recpond is a German employment recruiting company. Their services are delivered globally and include consulting and staffing solutions. In the beginning. Recpond provided its services through an office in Germany. Today, they have grown to become one of the largest recruiting agencies,providing employment to more than 500,000 people around the world. Recpond receives most applications through its website. Job searchers are required to provide the job title and location. Then, a list of job opportunities is provided. When a job position is selected, candidates are required to provide their contact details and professional work experience records. During the process, they are informed that the information will be used only for the purposes and period determined by Recpond. Recpond's experts analyze candidates' profiles and applications and choose the candidates that are suitable for the job position. The list of the selected candidates is then delivered to Recpond's clients, who proceed with the recruitment process. Files of candidates that are not selected are stored in Recpond's databases, including the personal data of candidates who withdraw the consent on which the processing was based. When the GDPR came into force, the company was unprepared.
The top management appointed a DPO and consulted him for all data protection issues. The DPO, on the other hand, reported the progress of all data protection activities to the top management. Considering the level of sensitivity of the personal data processed by Recpond, the DPO did not have direct access to the personal data of all clients, unless the top management deemed it necessary. The DPO planned the GDPR implementation by initially analyzing the applicable GDPR requirements. Recpond, on the other hand, initiated a risk assessment to understand the risks associated with processing operations. The risk assessment was conducted based on common risks that employment recruiting companies face. After analyzing different risk scenarios, the level of risk was determined and evaluated. The results were presented to the DPO, who then decided to analyze only the risks that have a greater impact on the company. The DPO concluded that the cost required for treating most of the identified risks was higher than simply accepting them. Based on this analysis, the DPO decided to accept the actual level of the identified risks. After reviewing policies and procedures of the company. Recpond established a new data protection policy. As proposed by the DPO, the information security policy was also updated. These changes were then communicated to all employees of Recpond.Based on this scenario, answer the following question:
Question:
Recpondstores files of candidates who are not selectedin its databases,even if they withdraw consent. Is this acceptable under GDPR?
- A. Yes, the GDPR only requires the controller tostop processing the datawhen consent is withdrawn but does not require its deletion.
- B. Yes, the GDPR allows personal data to be processedeven after consent is withdrawnso organizations can use the data for future recruitment opportunities.
- C. No, Recpond must retain candidate data for statistical analysis but must anonymize it.
- D. No, the GDPR requires the controller to erase personal data if the data subject withdraws their consent for data processing.
正解：D
質問 # 35
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. Yes, using personal data for creating health insurance plans is within the scope of the data collection purpose.
- C. No, personal data should be collected for specified, explicit, and legitimate purposes in accordance with Article 5 of GDPR.
- D. Yes, personal data may be used for purposes in the public interest or statistical purposes in accordance withArticle 89 of GDPR.
正解：C
質問 # 36
Question:
A patientgave consentfor the use of theirlaboratory teststo defend a clinical laboratory against a lawsuit. As a result, thecourt required the collection and processing of the patient's health data, and such information wasrevealed in court.
Is thiscompliantwith GDPR'slawfulness of processingrequirements?
- A. No, because personal data used in legal proceedings must be anonymized before being disclosed.
- B. No, although the data subject hasconsentedto the processing of health data, GDPR doesnotallow the disclosure of special categories of personal data by health institutions.
- C. Yes, but only if theprocessing of special categories of personal datais controlled by apublic health institution, and the data subject has consented to the processing of this type of data.
- D. Yes, because thedata subject has consentedto the processing of health data, and GDPR allows the processing of special categories of data where it is necessary for theestablishment, exercise, ordefense of legal claims.
正解：D
解説：
UnderArticle 9(2)(f) of GDPR, the processing ofspecial categories of data(e.g., health data) ispermitted without consentif it isnecessary for the establishment, exercise, or defense of legal claims.
* Option A is correctbecause GDPRallowsprocessing of special category datafor legal claims, even without explicit consent.
* Option B is incorrectbecause processing for legal claims isnot restricted to public health institutions
.
* Option C is incorrectbecause GDPRexplicitly allowssuch processing for legal claims.
* Option D is incorrectbecauseanonymization is not requiredwhen data is processed underArticle 9(2) (f).
References:
* GDPR Article 9(2)(f)(Processing of special categories of data for legal claims)
* Recital 52(Legal grounds for processing sensitive data in court cases)
質問 # 37
Scenario:
Ashop ownerdecided to install avideo surveillance systemto protect the property against theft. However, the cameras also capture a considerable part of the store next door.
Question:
Which statement below iscorrectin this case?
- A. Controllers or processors of personal data under this provisionfall under GDPR, since the cameras should capture only the premises of the shop owner who installed the cameras.
- B. GDPR does not applyto personal data collected by surveillance camerasif used for security purposes.
- C. Controllers or processors that provide the means of processing personal data for such activities should operate undercommunity privacy requirements.
- D. This provisiondoes not fall under GDPR requirementsas it does not pose a high threat to the rights and freedoms of data subjects.
正解：A
解説：
UnderArticle 2 of GDPR, the regulation applieswhenever personal data is processed by automated means
, includingCCTV footage that captures identifiable individuals.
* Option C is correctbecauseGDPR applies when surveillance cameras capture public or third- party areas beyond the shop owner's premises.
* Option A is incorrectbecausecommunity privacy requirements do not override GDPR.
* Option B is incorrectbecauseGDPR applies even if the risk is low, as long aspersonal data (images of identifiable individuals) is processed.
* Option D is incorrectbecauseGDPR applies to security cameras unless used solely for personal or household purposes(Recital 18).
References:
* GDPR Article 2(1)(Material scope includes video surveillance)
* Recital 18(Household exemption does not apply to public monitoring)
質問 # 38
Scenario4:
Berc is a pharmaceutical company headquartered in Paris, France, known for developing inexpensive improved healthcare products. They want to expand to developing life-saving treatments. Berc has been engaged in many medical researches and clinical trials over the years. These projects required the processing of large amounts of data, including personal information. Since 2019, Berc has pursued GDPR compliance to regulate data processing activities and ensure data protection. Berc aims to positively impact human health through the use of technology and the power of collaboration. They recently have created an innovative solution in participation with Unty, a pharmaceutical company located in Switzerland. They want to enable patients to identify signs of strokes or other health-related issues themselves. They wanted to create a medical wrist device that continuously monitors patients' heart rate and notifies them about irregular heartbeats. The first step of the project was to collect information from individuals aged between 50 and 65. The purpose and means of processing were determined by both companies. The information collected included age, sex, ethnicity, medical history, and current medical status. Other information included names, dates of birth, and contact details. However, the individuals, who were mostly Berc's and Unty's customers, were not aware that there was an arrangement between Berc and Unty and that both companies have access to their personal data and share it between them. Berc outsourced the marketing of their new product to an international marketing company located in a country that had not adopted the adequacy decision from the EU commission. However, since they offered a good marketing campaign, following the DPO's advice, Berc contracted it. The marketing campaign included advertisement through telephone, emails, and social media. Berc requested that Berc's and Unty's clients be first informed about the product. They shared the contact details of clients with the marketing company.Based on this scenario, answer the following question:
Question:
Based on scenario 4,Berc followed the DPO's advice for outsourcing an international marketing companyin the absence of an adequacy decision. Is the DPO responsible for evaluating this case?
- A. Yes, the DPO should evaluate cases where an adequacy decision is absent.
- B. Yes, the DPO takes the final decision on transferring personal data to an international company in the absence of an adequacy decision.
- C. No, the controller or processor should evaluate cases when the adequacy decision is absent.
- D. No, because the marketing company operates under the same data protection rules as Berc.
正解：C
解説：
UnderArticle 44 of GDPR, thecontroller (Berc)is responsible forensuring lawful data transfers. TheDPO advises on compliancebut doesnot make final decisionson data transfers.
* Option C is correctbecause thecontroller (Berc) must evaluate the legality of the transfer.
* Option A is incorrectbecauseDPOs provide advice but do not evaluate data transfer legality.
* Option B is incorrectbecauseDPOs do not have executive decision-making authority.
* Option D is incorrectbecausedata protection rules vary by jurisdiction, making this assumption incorrect.
References:
* GDPR Article 44(General principle for transfers)
* GDPR Article 39(1)(a)(DPO's advisory role)
質問 # 39
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:
Which de-identification method has MA store used when analyzing the shopping preferences of its customers?
- A. Differential privacy
- B. Scrambling
- C. Generalizing data with k-anonymity
正解：C
解説：
MA Store replaces customer identities with a common value when analyzing shopping preferences, ensuring that the data subject's identity cannot be retrieved. This method aligns withk-anonymity, where personal identifiers are removed or generalized to protect individuals from re-identification. The goal of k-anonymity is to prevent unique identification by ensuring that each data entry is indistinguishable from at least k-1 other entries. This is an effective way to process data while maintaining compliance with GDPR principles of data minimization (Article 5(1)(c)) and anonymization.
質問 # 40
Scenario:
Pinky, a retail company,received a requestfrom adata subjectto identify which purchasesthey had madeat differentphysical store locations. However,Pinky does not link purchase records to customer identities, since purchasesdo not require account creation.
Question:
Should Pinkyprocess additional informationfrom customers in order toidentify the data subjectas requested?
- A. No, Pinky isnot requiredto process additional information, since the processing of personal data in this case does not require Pinky toidentify the data subject.
- B. Yes, Pinky is required to process additional information for the purpose ofexercising the data subject' s rightscovered inArticles 15-21 of GDPR.
- C. No, but Pinky must ask the data subject to provide further evidence proving their identity.
- D. Yes, Pinky is required tomaintain, acquire, or process additional informationin order to identify the data subject.
正解：A
解説：
UnderArticle 11(1) of GDPR, controllersare not required to process additional datafor the sole purpose of identifying data subjectsif such identification is not needed for processing.
* Option C is correctbecausePinky does not store identifiable purchase data, so it is not required to create additional records.
* Option A and B are incorrectbecauseGDPR does not obligate controllers to process additional data if identification is unnecessary.
* Option D is incorrectbecausePinky cannot require additional information when it does not have a basis to process identity-linked data.
References:
* GDPR Article 11(1)(Controllers are not required to process extra data for identification)
* Recital 57(Data controllers should avoid collecting unnecessary identity data)
質問 # 41
Scenario4:
Berc is a pharmaceutical company headquartered in Paris, France, known for developing inexpensive improved healthcare products. They want to expand to developing life-saving treatments. Berc has been engaged in many medical researches and clinical trials over the years. These projects required the processing of large amounts of data, including personal information. Since 2019, Berc has pursued GDPR compliance to regulate data processing activities and ensure data protection. Berc aims to positively impact human health through the use of technology and the power of collaboration. They recently have created an innovative solution in participation with Unty, a pharmaceutical company located in Switzerland. They want to enable patients to identify signs of strokes or other health-related issues themselves. They wanted to create a medical wrist device that continuously monitors patients' heart rate and notifies them about irregular heartbeats. The first step of the project was to collect information from individuals aged between 50 and 65. The purpose and means of processing were determined by both companies. The information collected included age, sex, ethnicity, medical history, and current medical status. Other information included names, dates of birth, and contact details. However, the individuals, who were mostly Berc's and Unty's customers, were not aware that there was an arrangement between Berc and Unty and that both companies have access to their personal data and share it between them. Berc outsourced the marketing of their new product to an international marketing company located in a country that had not adopted the adequacy decision from the EU commission. However, since they offered a good marketing campaign, following the DPO's advice, Berc contracted it. The marketing campaign included advertisement through telephone, emails, and social media. Berc requested that Berc's and Unty's clients be first informed about the product. They shared the contact details of clients with the marketing company.Based on this scenario, answer the following question:
Question:
Based on scenario 4, to which of the companies candata subjects exercise their rightsunder GDPR?
- A. Data subjects may exercise their rights againstonly one of the controllers, as specified in the arrangement.
- B. Data subjects may exercise their rights againstboth Berc and Unty, regardless of the terms of the arrangement.
- C. Data subjects may exercise their rights againstBerc onlybecause it decided to implement GDPR for data processing activities.
- D. None of the above.
正解：B
解説：
References:
* GDPR Article 26(3)(Joint controllers must ensure data subjects can exercise their rights).
質問 # 42
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 all security-related tasks, including updating GDPR policies.
- B. No, the DPO is responsible for monitoring compliance with GDPR butnotfor implementing the GDPR compliance policies.
- C. No, the DPO is only responsible for proposing changes and obtaining evidence regarding specific GDPR requirements in the policy.
- D. Yes, the DPO is responsible for implementing GDPR policies, procedures, and processes, as well as ensuring compliance.
正解：B
解説：
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)
質問 # 43
Scenario:
BookStis anonline bookshopthat collectspersonal databefore selling its products.Sarah signed up for an account, providing hername, email, and password. To purchase a book, Sarah was required to provide her shipping address and payment information, which isneeded to calculate shipping costsandcomplete the transaction.
Question:
Does the company have alegal basisfor processing Sarah's data?
- A. No, the processing is legally justified only if it is necessary toprotect the vital interests of the data subject.
- B. Yes, but only if Sarah providesexplicit consentfor her data to be processed.
- C. No, the processing isnot legally justifiedif it is only for sales purposes.
- D. Yes, the processing is necessary for theperformance of a contractto which the data subject is a party.
正解：D
解説：
References:
* GDPR Article 6(1)(b)(Processing necessary for contract performance)
* Recital 44(Contractual necessity as a legal basis)
質問 # 44
Scenario 7: EduCCS is an online education platform based in Netherlands. EduCCS helps organizations find, manage, and deliver their corporate training. Most of EduCCS's clients are EU residents. EduCCS is one of the few education organizations that have achieved GDPR compliance since 2019. Their DPO is a full-time employee who has been engaged in most data protection processes within the organization. In addition to facilitating GDPR compliance, the DPO acts as an intermediary point between EduCCS and other relevant interested parties. EduCCS's users canbenefit from the variety of up-to-date training library and the possibility of accessing it through their phones, tablets, or computers. EduCCS's services are offered through two main platforms: online learning and digital training. To use one of these platforms, users should sign on EduCCS's website by providing their personal information. Online learning is a platform in which employees of other organizations can search for and request the training they need. Through its digital training platform, on the other hand, EduCCS manages the entire training and education program for other organizations.
Organizations that need this type of service need to provide information about their core activities and areas where training sessions are needed. This information is then analyzed by EduCCS and a customized training program is provided. In the beginning, all IT-related services were managed by two employees of EduCCS.
However, after acquiring a large number of clients, managing these services became challenging That is why EduCCS decided to outsource the IT service function to X-Tech. X-Tech provides IT support and is responsible for ensuring the security of EduCCS's network and systems. In addition, X-Tech stores and archives EduCCS's information including their training programs and clients' and employees' data. Recently, X-Tech made headlines in the technology press for being a victim of a phishing attack. A group of three attackers hacked X-Tech's systems via a phishing campaign which targeted the employees of the Marketing Department. By compromising X-Tech's mail server, hackers were able to gain access to more than 200 computer systems. Consequently, access to the networks of EduCCS's clients was also allowed. Using EduCCS's employee accounts, attackers installed a remote access tool on EduCCS's compromised systems.
By doing so, they gained access to personal information of EduCCS's clients, training programs, and other information stored in its online payment system. The attack was detected by X-Tech's system administrator.
After detecting unusual activity in X-Tech's network, they immediately reported it to the incident management team of the company. One week after being notified about the personal data breach, EduCCS communicated the incident to the supervisory authority with a document that outlined the reasons for the delay revealing that due to the lack of regular testing or modification, their incident response plan was not adequately prepared to handle such an attack.Based on this scenario, answer the following question:
Question:
ShouldEduCCS document information related to the personal data breach, includingfacts, its impact, and the remedial action taken?
- A. Yes, EduCCS should document any personal data breachto enable the supervisory authority to verify compliancewithGDPR's Article 33(Notification of a personal data breach to the supervisory authority).
- B. No, EduCCS must report the breachonly if more than 100,000 individuals were affected.
- C. No, EduCCS wasnot the direct target of the attack, so itcannot document details about the breach, its impact, or remedial actions.
- D. Yes, EduCCS should document the personal data breachto allow the supervisory authority to determine if the breach must be communicated to data subjects.
正解：A
解説：
UnderArticle 33(5) of GDPR, controllers mustdocument personal data breaches, including their effects and corrective measures, even if notification to data subjects is not required.
* Option A is correctbecausedocumentation is mandatory for compliance verification.
* Option B is incorrectbecausedocumentation is required regardless of whether notification to data subjects is necessary.
* Option C is incorrectbecauseEduCCS, as the controller, is responsible for breach documentation.
* Option D is incorrectbecauseGDPR does not impose a breach reporting threshold based on the number of affected individuals.
References:
* GDPR Article 33(5)(Documentation of breaches)
* Recital 85(Controllers must record breaches and mitigation actions)
質問 # 45
Why should the controller implement appropriate technical and organizational measures?
- A. To allow the data subject to monitor the processing of their personal data
- B. To maximize the processing of personal data
- C. To enable the processor to create and improve security features
正解：A
解説：
GDPR Article 25 requires controllers to implement appropriate measures ensuring data protection. This includes transparency measures that allow data subjects to monitor the processing of their personal data, fulfilling their rights under Articles 12-22.
質問 # 46
Scenario:
Bankbiois a financial institution that handlespersonal dataof its customers. Itsdata processing activities involve processingthat is necessary for thelegitimate interestspursued by the institution. In such cases, Bankbio processes personal datawithout obtaining consent from data subjects.
Question:
Is the data processinglawful under GDPR?
- A. No, financial institutionsmust always obtain explicit consentbefore processing personal data.
- B. No, the processing is lawfulonly if the data subject has given explicit consentto the processing of personal data for the specified purpose.
- C. Yes, GDPR allows the processing of personal data for thelegitimate interest pursued by the controller or by a third party in all cases.
- D. Yes, processing is lawful when it is necessary for thelegitimate interestspursued by the controller, except where such interests are overridden by the interests of fundamental rights.
正解：D
解説：
UnderArticle 6(1)(f) of GDPR, processing is lawful if it isnecessary for the legitimate interests of the controller, unlessoverridden by the data subject's rights and freedoms.
* Option A is correctbecauselegitimate interest is a valid legal basis for processingunder GDPR.
* Option B is incorrectbecauseexplicit consent is not requiredif another legal basis (such as legitimate interest) applies.
* Option C is incorrectbecauselegitimate interest does not apply in all cases-the rights of the data subject may override it.
* Option D is incorrectbecausefinancial institutions are not required to obtain explicit consent for all processing activities.
References:
* GDPR Article 6(1)(f)(Legitimate interest as a lawful basis)
* Recital 47(Legitimate interest includes preventing fraud and ensuring security)
質問 # 47
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, Soyled only has threemandatory fieldsin its sign-up form. On which GDPR principle is this decision based?
- A. Data minimization
- B. Purpose limitation
- C. Lawfulness, fairness, and transparency
- D. Storage limitation
正解：A
解説：
UnderArticle 5(1)(c) of GDPR, thedata minimization principlestates that personal data must beadequate, relevant, and limited to what is necessaryfor processing.
Soyled'sdecision to have only three mandatory fields(name, surname, and email) aligns withdata minimizationsince itonly collects the minimum data neededfor account creation.Option C is correct.
Option Ais incorrect as transparency relates to informing users.Option Bis incorrect because purpose limitation focuses on using data only for specific purposes.Option Dis incorrect because storage limitation concernsdata retention periods.
References:
* GDPR Article 5(1)(c)(Data minimization principle)
* Recital 39(Limiting data collection to necessity)
質問 # 48
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