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IAPP Exam CIPP-E 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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Rosendo
5 days 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
18 days ago
I think a dynamic IP address is considered personal data when combined with other data held by the processor.
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