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IAPP AIGP Exam - Topic 1 Question 50 Discussion

CASE STUDYA company is considering the procurement of an AI system designed to enhance the security of IT infrastructure. The AI system analyzes how users type on their laptops, including typing speed, rhythm and pressure, to create a unique user profile. This data is then used to authenticate users and ensure that only authorized personnel can access sensitive resources.The data processed by the AI system would be classified as:
D) Special category data, if it can be used to uniquely identify a person
A) Non-sensitive personal data, since it does not reveal information about health, gender or race
B) Organizational data, since it is part of the authentication process
C) Non-personal data, as long as it is not linked to a user ID

IAPP AIGP Exam - Topic 1 Question 50 Discussion

Actual exam question for IAPP's AIGP exam
Question #: 50
Topic #: 1
[All AIGP Questions]

CASE STUDY

A company is considering the procurement of an AI system designed to enhance the security of IT infrastructure. The AI system analyzes how users type on their laptops, including typing speed, rhythm and pressure, to create a unique user profile. This data is then used to authenticate users and ensure that only authorized personnel can access sensitive resources.

The data processed by the AI system would be classified as:

Show Suggested Answer Hide Answer
Suggested Answer: D

The correct answer is D. Key stroke dynamics, used to identify individuals, fall under biometric data, which is a special category of personal data under the GDPR and other frameworks.

From the AI Governance in Practice Report 2025:

''Keystroke dynamics may constitute biometric data if used to uniquely identify an individual... Biometric data is classified as special category personal data and requires higher protection standards.''

Also reflected in ILT Participant Guide:

''Biometric data, such as facial images, voiceprints, iris scans or keystroke patterns, are treated as special category data when they are used for the purpose of uniquely identifying individuals.''


by Eileen at Aug 14, 2026, 07:00 AM

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Joseph
15 hours ago
Totally agree with Nickie, it's about security!
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Shawnda
6 days ago
Wait, isn't this a bit invasive?
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Nickie
11 days ago
I think it's organizational data since it's for authentication.
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King
16 days ago
This data definitely seems like it could identify a person.
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Ricarda
21 days ago
I think option D could be correct if the typing data is unique enough to identify someone. But I’m also considering option C, especially if it’s not linked to a user ID.
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Ines
26 days ago
I’m confused about option A. Just because it doesn’t reveal health or race doesn’t mean it’s non-sensitive, right? I feel like it could still be personal data.
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Cordelia
1 month ago
This reminds me of a practice question where we classified data types. I think option B makes sense since it’s used for authentication, but I’m hesitant about the implications of user profiling.
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Francesco
1 month ago
I remember discussing how biometric data can be sensitive, so I’m leaning towards option D, but I’m not entirely sure if typing patterns count as special category data.
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