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Exam CIPP-E topic 1 question 53 discussion

Actual exam question from IAPP's CIPP-E
Question #: 53
Topic #: 1
[All CIPP-E Questions]

SCENARIO -
Please use the following to answer the next question:
Liem, an online retailer known for its environmentally friendly shoes, has recently expanded its presence in Europe. Anxious to achieve market dominance, Liem teamed up with another eco friendly company, EcoMick, which sells accessories like belts and bags. Together the companies drew up a series of marketing campaigns designed to highlight the environmental and economic benefits of their products. After months of planning, Liem and EcoMick entered into a data sharing agreement to use the same marketing database, MarketIQ, to send the campaigns to their respective contacts.
Liem and EcoMick also entered into a data processing agreement with MarketIQ, the terms of which included processing personal data only upon Liem and EcoMick’s instructions, and making available to them all information necessary to demonstrate compliance with GDPR obligations.
Liem and EcoMick then procured the services of a company called JaphSoft, a marketing optimization firm that uses machine learning to help companies run successful campaigns. Clients provide JaphSoft with the personal data of individuals they would like to be targeted in each campaign. To ensure protection of its clients’ data, JaphSoft implements the technical and organizational measures it deems appropriate. JaphSoft works to continually improve its machine learning models by analyzing the data it receives from its clients to determine the most successful components of a successful campaign. JaphSoft then uses such models in providing services to its client-base. Since the models improve only over a period of time as more information is collected, JaphSoft does not have a deletion process for the data it receives from clients. However, to ensure compliance with data privacy rules, JaphSoft pseudonymizes the personal data by removing identifying information from the contact information. JaphSoft’s engineers, however, maintain all contact information in the same database as the identifying information.
Under its agreement with Liem and EcoMick, JaphSoft received access to MarketIQ, which included contact information as well as prior purchase history for such contacts, to create campaigns that would result in the most views of the two companies’ websites. A prior Liem customer, Ms. Iman, received a marketing campaign from JaphSoft regarding Liem’s as well as EcoMick’s latest products. While Ms. Iman recalls checking a box to receive information in the future regarding Liem’s products, she has never shopped EcoMick, nor provided her personal data to that company.
For what reason would JaphSoft be considered a controller under the GDPR?

  • A. It determines how long to retain the personal data collected.
  • B. It has been provided access to personal data in the MarketIQ database.
  • C. It uses personal data to improve its products and services for its client-base through machine learning.
  • D. It makes decisions regarding the technical and organizational measures necessary to protect the personal data.
Show Suggested Answer Hide Answer
Suggested Answer: C 🗳️

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Ssourav
4 months ago
Selected Answer: C
C. It uses personal data to improve its products and services for its client-base through machine learning. GDPR Article Reference: Article 4(7): The GDPR defines a controller as the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
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0cd43a1
5 months ago
Under the GDPR, a controller is defined as the entity that determines the purposes and means of the processing of personal data. Deciding how long to retain personal data is a key aspect of determining the means of data processing, thereby making JaphSoft a controller. The other options involve activities that can also be associated with processors or other roles but do not alone define the entity as a controller.
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0cd43a1
5 months ago
After reviewing further the correct answer is C. JaphSoft is a controller because it decides to use personal data to improve its machine learning models, determining the purpose of processing.
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