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Exam CIPP-E topic 1 question 22 discussion

Actual exam question from IAPP's CIPP-E
Question #: 22
Topic #: 1
[All CIPP-E Questions]

What is the consequence if a processor makes an independent decision regarding the purposes and means of processing it carries out on behalf of a controller?

  • A. The controller will be liable to pay an administrative fine
  • B. The processor will be liable to pay compensation to affected data subjects
  • C. The processor will be considered to be a controller in respect of the processing concerned
  • D. The controller will be required to demonstrate that the unauthorized processing negatively affected one or more of the parties involved
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Suggested Answer: C 🗳️

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Ssourav
4 months, 1 week ago
Selected Answer: C
C. The processor will be considered to be a controller in respect of the processing concerned. Under the GDPR, if a processor goes beyond the instructions given by the controller and determines the purposes and means of processing, it is no longer acting as a processor but as a controller in its own right for that particular processing activity. This reclassification has significant implications, as it means the processor assumes all the responsibilities and obligations of a controller under the GDPR. Why not D : The main consequence is not about demonstrating harm but about the reclassification and the shift in responsibility. When a processor decides the purposes and means of processing, it is automatically considered a controller for those decisions, irrespective of whether harm can be demonstrated.
upvoted 3 times
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OSXmaniac
9 months, 2 weeks ago
Selected Answer: C
If a processor makes independent decisions regarding the purposes and means of processing it carries out on behalf of a controller, it steps beyond its role as a processor and takes on the role of a controller for that specific processing activity. This shift in roles means that the processor assumes the legal responsibilities and obligations of a controller for those decisions.
upvoted 3 times
february123
9 months, 2 weeks ago
Agree - If a processor acts outside of a controller's instructions in such a way that it decides the purpose and means of processing, then it will be a controller and will have the same liability as a controller. https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/accountability-and-governance/contracts-and-liabilities-between-controllers-and-processors-multi/responsibilities-and-liabilities-for-processors-in-their-own-right/#:~:text=If%20a%20processor%20acts%20outside,same%20liability%20as%20a%20controller.
upvoted 2 times
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moxiangnaicha
1 year ago
Selected Answer: D
In such a case, the controller may be held accountable for the actions of the processor and will need to provide evidence that the unauthorized processing had a negative impact on the parties involved.
upvoted 1 times
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