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Exin PDPF Exam - Topic 9 Question 93 Discussion

Posted by Thad on Jan 05, 2026 at 05:16 AM

A controller asks a processor to produce a report containing customers who have purchased a particular product more than once in the past 6 months.

The processor provides services to several companies (which in this case are the controllers).

When generating the requested report, it uses customer data collected by another controller, that is, for a different purpose.

Fortunately, the error is noticed in time, the report is not sent, and nobody has had access to this dat

a. In this case, how does the processor need to proceed and what action should the controller take?

Suggested Answer: B

In the example there is likely to be no risk to the data subjects or if it exists it will be very low, but this does not exempt the processor from notifying the Controller. However, at least the Controller should assess whether there is a need to notify the Supervisory Authority.


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27 comments · newest first
NO
Norah 6 months ago
I feel like option A is overkill. Just notify the controller, right?
MI
Ming 6 months ago
Option D seems too relaxed. We can't ignore the error.
JU
Judy 6 months ago
I agree, but what if there were risks? Option C might be safer.
TI
Tiara 6 months ago
I think option B is the best. Notify the controller first.
NO
Novella 6 months ago
I’m surprised they even used data from another controller like that!
VE
Veronique 7 months ago
Option C is the best choice, they need to inform the authority.
KE
Kenny 7 months ago
Wait, are you saying they don’t have to notify anyone since it was caught in time? That seems risky!
LE
Leatha 7 months ago
I agree, option B makes the most sense here.
DE
Detra 7 months ago
The processor should definitely notify the controller.
CA
Casie 7 months ago
I'm just glad I don't have to deal with this kind of data privacy headache. I'll stick to my job of making sure the coffee machine is always full.
DO
Dorthy 8 months ago
Option C is the way to go. The processor should notify the controller, and the controller should then notify the Supervisory Authority. Better safe than sorry, right?
LO
Louisa 8 months ago
Hmm, I'm not sure. This seems like a tricky situation. Maybe the processor should just go with their gut and delete the report, no need to bother the controller.
VI
Vivan 8 months ago
Option D is tempting, but it's better to be safe than sorry. The processor should notify the controller, just to be on the right side of the law.
AH
Ahmad 9 months ago
I agree with Antonio. The processor should notify the controller, and the controller can take the necessary actions.
AN
Antonio 9 months ago
Option B seems the most appropriate. The processor should notify the controller, and the controller can then assess the risks to the data subjects.
CA
Catarina 9 months ago
I feel like the controller has to assess risks if the processor notifies them, so maybe option B is the best choice after all.
HA
Haydee 9 months ago
I'm a bit confused about whether the error being caught in time changes the requirement to notify anyone. I think option D might be too simplistic.
LI
Ligia 9 months ago
I remember a practice question where the processor had to inform the controller about a data breach. I feel like option B makes sense here too.
SA
Salina 9 months ago
I think the processor should notify the controller, but I'm not sure if they also need to inform the Supervisory Authority since the report wasn't sent.
KR
Kristine 10 months ago
Ah, I see. Since the error was caught before the report was sent, that changes things. I'll need to weigh the options carefully to determine the best course of action.
SH
Shawna 10 months ago
I think the safest approach is to notify the controller and let them handle it from there. Better to err on the side of caution when it comes to personal data breaches.
CH
Christoper 10 months ago
I'm a bit confused on the roles here - is the processor the one who generated the report, or the one who collects the customer data? That feels important to understand.
BO
Bo 10 months ago
Okay, let's see. The key seems to be that the data was collected for a different purpose, so that could be a problem. I'll need to review the privacy policies and regulations carefully.
AL
Alida 10 months ago
Hmm, this seems like a tricky one. I'll need to really think through the data protection implications here.
MU
Muriel 4 months ago
↳ replying to Alida
But if the report wasn’t sent, maybe it’s not a big deal?
MA
Mable 4 months ago
↳ replying to Alida
Definitely! The controller needs to assess the risks involved.
SH
Sharan 4 months ago
↳ replying to Alida
I think the processor should notify the controller right away.
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