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Exam CIPP-E topic 1 question 161 discussion

Actual exam question from IAPP's CIPP-E
Question #: 161
Topic #: 1
[All CIPP-E Questions]

SCENARIO -
Please use the following to answer the next question:
BHealthy, a company based in Italy, is ready to launch a new line of natural products, with a focus on sunscreen. The last step prior to product launch is for BHealthy to conduct research to decide how extensively to market its new line of sunscreens across Europe. To do so, BHealthy teamed up with Natural Insight, a company specializing in determining pricing for natural products. BHealthy decided to share its existing customer information – name, location, and prior purchase history – with Natural Insight. Natural Insight intends to use this information to train its algorithm to help determine the price point at which BHealthy can sell its new sunscreens.
Prior to sharing its customer list, BHealthy conducted a review of Natural Insight’s security practices and concluded that the company has sufficient security measures to protect the contact information. Additionally, BHealthy’s data processing contractual terms with Natural Insight require continued implementation of technical and organization measures. Also indicated in the contract are restrictions on use of the data provided by BHealthy for any purpose beyond provision of the services, which include use of the data for continued improvement of Natural Insight’s machine learning algorithms.
What is the nature of BHealthy and Natural Insight’s relationship?

  • A. Natural Insight is BHealthy’s processor because the companies entered into data processing terms.
  • B. Natural Insight is BHealthy’s processor because BHealthy is sharing its customer information with Natural Insight.
  • C. Natural Insight is the controller because it determines the security measures to implement to protect data it processes; BHealthy is a co-controller because it engaged Natural Insight to determine pricing for the new sunscreens.
  • D. Natural Insight is a controller because it is separately determining the purpose of processing when it uses BHealthy’s customer information to improve its machine learning algorithms.
Show Suggested Answer Hide Answer
Suggested Answer: D 🗳️

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Egofskam
Highly Voted 1 year, 3 months ago
Selected Answer: D
I really think it is D given Natural Insight is determining the purpose for processing. While C is close, BHealthy is actually a controller because of its use and control of the data, not because its intent to determine pricing information...
upvoted 6 times
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Ssourav
Most Recent 3 months, 3 weeks ago
Selected Answer: D
In this scenario: BHealthy is sharing its customer information with Natural Insight for a specific purpose (determining the price point for the new sunscreens). Natural Insight is using this data to train its algorithms and improve its services, which implies that it has some level of control over the data and is determining additional purposes for the data processing beyond the specific instructions of BHealthy. This makes Natural Insight a controller in its own right for the processing activities related to the improvement of its machine learning algorithms, while BHealthy can still be considered a controller for the initial purpose of sharing the data (pricing determination). Therefore, the correct answer is D.
upvoted 1 times
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hele_meneer
11 months ago
Selected Answer: D
D, because BH did not set the means and goals of using the data to train NI's AI
upvoted 3 times
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moxiangnaicha
1 year ago
Selected Answer: A
I agree with A.
upvoted 3 times
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tubcippe
1 year ago
A should be the answer
upvoted 2 times
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