CIPP-E practice question 19 of 35
SCENARIO Please use the following to answer the next question: Liem, an online retailer known for its environmentally friendly shoes, has recently…
Choose your answer, then check it against the explanation.
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.
Under the GDPR, Liem and EcoMick’s contract with MarketIQ must include all of the following
provisions EXCEPT?
Question 19 of 35
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