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Exam CIPP-E topic 1 question 189 discussion

Actual exam question from IAPP's CIPP-E
Question #: 189
Topic #: 1
[All CIPP-E Questions]

SCENARIO -
Please use the following to answer the next question:
ABC Hotel Chain and XYZ Travel Agency are U.S.-based multinational companies. They use an internet-based common platform for collecting and sharing their customer data with each other, in order to integrate their marketing efforts. Additionally, they agree on the data to be stored, how reservations will be booked and confirmed, and who has access to the stored data.
Mike, an EU resident, has booked travel itineraries in the past through XYZ Travel Agency to stay at ABC Hotel Chain’s locations. XYZ Travel Agency offers a rewards program that allows customers to sign up to accumulate points that can later be redeemed for free travel. Mike has signed the agreement to be a rewards program member.
Now Mike wants to know what personal information the company holds about him. He sends an email requesting access to his data, in order to exercise what he believes are his data subject rights.
In which of the following situations would ABC Hotel Chain and XYZ Travel Agency NOT have to honor Mike’s data access request?

  • A. The request is to obtain access and correct inaccurate personal data in his profile.
  • B. The request is to obtain access and information about the purpose of processing his personal data.
  • C. The request is to obtain access and erasure of his personal data while keeping his rewards membership.
  • D. The request is to obtain access and the categories of recipients who have received his personal data to process his rewards membership.
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Suggested Answer: C 🗳️
by Ssourav at Aug. 6, 2024, 3:56 a.m.

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Ssourav
3 months, 3 weeks ago
Selected Answer: C
C. The request is to obtain access and erasure of his personal data while keeping his rewards membership. Under the GDPR, a data subject has the right to access and erasure of personal data. However, if Mike requests the erasure of his personal data while still wanting to maintain his rewards membership, it creates a conflict. The rewards program likely relies on the personal data to function, and erasure of that data would make it impossible to maintain the membership. Therefore, ABC Hotel Chain and XYZ Travel Agency would not be able to honor the request to erase his personal data while keeping his rewards membership intact.
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