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IAPP CIPP-E Exam - Topic 1 Question 109 Discussion

Actual exam question for IAPP's CIPP-E exam
Question #: 109
Topic #: 1
[All CIPP-E Questions]

A dynamic Internet Protocol (IP) address is considered persona! data when it is combined with what?

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Suggested Answer: B

A dynamic IP address is a unique numerical label for a device on the internet that changes every time the device connects to the internet. A dynamic IP address by itself is not personal data, as it does not directly identify the person who owns or uses the device. However, a dynamic IP address can become personal data when it is combined with other data held by the controller, such as the web pages accessed by the device, the time and duration of the visit, the location of the device, or the user's preferences and interests. In this case, the controller can use the additional data to identify the data subject, either directly or indirectly, by linking the dynamic IP address to a specific person or a profile. This was confirmed by the Court of Justice of the European Union (CJEU) in the case of Breyer v Bundesrepublik Deutschland, where the CJEU ruled that a dynamic IP address registered by a website provider constitutes personal data in relation to that provider, where the latter has the legal means to obtain the identity of the data subject from the internet service provider (ISP) that assigned the dynamic IP address. Therefore, option B is the correct answer.Reference:Directive 95/46/EC,Directive 2002/58/EC,Breyer v Bundesrepublik Deutschland, Case C-582/14,Dynamic IP Addresses can be Personal Data


by Cory at Jul 03, 2025, 03:02 PM

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Gladys
3 months ago
I thought it was just ISPs that mattered for this.
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Vivienne
3 months ago
Totally agree, that's how it becomes personal!
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Alexia
3 months ago
Other data held by the processor makes sense too!
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Jennie
3 months ago
Wait, are we sure about that? Seems a bit off.
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Gail
4 months ago
It's combined with other data held by the controller.
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Cristina
4 months ago
I think it’s definitely about other data held by recipients, but I might be mixing it up with another question we practiced.
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Dianne
4 months ago
I feel like it could also be about ISPs, but I can't recall if that's specifically mentioned in the regulations.
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Glynda
4 months ago
I remember a practice question about data controllers and how they relate to personal data. Maybe option B is correct?
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Arminda
4 months ago
I think a dynamic IP address is considered personal data when it's combined with other data held by the processor, but I'm not entirely sure.
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Phillip
5 months ago
I'm not totally sure about this one. I'll need to weigh the options carefully and try to eliminate any answers that don't seem quite right.
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Aracelis
5 months ago
Okay, I've got this. The key is understanding what qualifies as "personal data" when combined with an IP address. I think I know the right answer here.
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Garry
5 months ago
Hmm, I'm a bit confused about the distinction between a "dynamic IP address" and other types of IP addresses. I'll need to review my notes on that.
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Fausto
5 months ago
This seems like a straightforward question about data privacy. I'll need to think carefully about the relationship between IP addresses and personal data.
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Timothy
7 months ago
This question is a real IP-head-scratcher! But I'm going with C. Gotta protect that personal data, you know?
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Danica
6 months ago
I agree with you, C is the best choice to protect personal data.
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Chara
6 months ago
I'm not sure, but I think it's B. The controller probably has important data too.
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Wendell
7 months ago
I think it's A. The processor holds a lot of data.
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Mona
7 months ago
I hope the exam doesn't ask us to guess the IP address of the person next to us. That would be a real breach of privacy!
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Rosendo
7 months ago
I think both the processor and the controller holding other data could make the IP address personal data. It's all about the context and how the data is being used.
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Whitley
8 months ago
Hmm, I'm not sure. I was thinking it would be D, with data held by the ISP. But C makes sense too.
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Erick
7 months ago
Yeah, combining the dynamic IP address with data held by recipients could definitely make it personal data.
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Arlene
7 months ago
I agree, C does make sense in this context.
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Cheryl
7 months ago
I think it's C, with other data held by recipients of the data.
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Cassi
8 months ago
Definitely B. The IP address is personal data when combined with data held by the controller.
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Thersa
8 months ago
That's a good point, Felicitas. The controller also has access to personal information, so combining it with an IP address could also be considered personal data.
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Alishia
8 months ago
I think the answer is C. The IP address becomes personal data when combined with other data held by recipients.
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Yoko
7 months ago
B: I think it's B. The IP address is considered personal data when combined with other data held by the controller.
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Aimee
7 months ago
A: I believe the answer is A. It becomes personal data when combined with other data held by the processor.
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Felicitas
8 months ago
But what about other data held by the controller? Wouldn't that also make the IP address personal data?
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Rosendo
8 months ago
I agree with Thersa. The processor has access to a lot of personal information, so combining it with an IP address could definitely be considered personal data.
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Thersa
8 months ago
I think a dynamic IP address is considered personal data when combined with other data held by the processor.
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