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IAPP CIPP-E Exam - Topic 3 Question 120 Discussion

A well-known video production company, based in Spain but specializing in documentaries filmed worldwide, has just finished recording several hours of footage featuring senior citizens in the streets of Madrid. Under what condition would the company NOT be required to obtain the consent of everyone whose image they use for their documentary?
D) If the company's status as a documentary provider allows it to claim legitimate interest.
A) If obtaining consent is deemed to involve disproportionate effort.
B) If obtaining consent is deemed voluntary by local legislation.
C) If the company limits the footage to data subjects solely of legal age.

IAPP CIPP-E Exam - Topic 3 Question 120 Discussion

Actual exam question for IAPP's CIPP-E exam
Question #: 120
Topic #: 3
[All CIPP-E Questions]

A well-known video production company, based in Spain but specializing in documentaries filmed worldwide, has just finished recording several hours of footage featuring senior citizens in the streets of Madrid. Under what condition would the company NOT be required to obtain the consent of everyone whose image they use for their documentary?

Show Suggested Answer Hide Answer
Suggested Answer: D

According to the GDPR, consent is one of the six lawful bases for processing personal data, but not the only one. The other five are: contract, legal obligation, vital interests, public task and legitimate interests. Legitimate interests can be invoked by controllers who process personal data for their own benefit or for the benefit of third parties, as long as such processing does not override the rights and freedoms of the data subjects, especially if they are children. The GDPR also recognizes that processing personal data for journalistic purposes or the purposes of academic, artistic or literary expression may be necessary for the exercise of the right to freedom of expression and information, which is a legitimate interest. Therefore, the company may not need to obtain the consent of everyone whose image they use for their documentary, if they can demonstrate that their processing is necessary for the purposes of their journalistic, artistic or literary expression, and that they have taken into account the reasonable expectations of the data subjects and the potential impact on their privacy. The company should also comply with any relevant national laws or codes of conduct that may apply to such processing.Reference:

GDPR, Article 6(1)(a)-(f)

GDPR, Recital 47

GDPR, Article 85


by Nobuko at Apr 10, 2026, 10:35 AM

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Kara
B is interesting too. Local laws might allow it.
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Kattie
5 days ago
I agree, but what about D? Legitimate interest sounds strong for documentaries.
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Vonda
10 days ago
I think A makes sense. Disproportionate effort could be a valid reason.
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Shawna
15 days ago
I’m leaning towards A as well. It’s practical for filmmakers.
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Cammy
20 days ago
I feel like D is the safest bet. Documentaries often have that leeway.
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Meghan
26 days ago
A is definitely a good point. Sometimes getting consent is just too hard.
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Johnna
1 month ago
What about B? If local laws say it's voluntary, that could work.
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Stevie
1 month ago
I agree, but D seems strong too. Legitimate interest is key for documentaries.
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Javier
1 month ago
I think A makes sense. Disproportionate effort is a valid reason.
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Macy
2 months ago
C) doesn't really apply here, age doesn't matter for consent.
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Ronnie
2 months ago
B) is tricky, local laws vary a lot.
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Jamie
2 months ago
Wait, so they can film without consent? That feels sketchy!
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Kayleigh
2 months ago
I disagree, D) seems more valid for documentaries.
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Artie
2 months ago
A) is the right answer! Disproportionate effort makes sense.
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Rosann
2 months ago
Disagree with D, consent should always be a priority!
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Felicidad
3 months ago
I think D could work too, but A seems safer.
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Delila
3 months ago
Wait, is that really a thing? Sounds sketchy.
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Brinda
4 months ago
Totally agree with A! Makes sense for documentaries.
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Cherelle
5 months ago
A) If obtaining consent is deemed to involve disproportionate effort.
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Kimbery
5 months ago
I lean towards option D since documentaries often have a different standard for consent, but I’m not completely confident about the legal implications.
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Elenora
5 months ago
I feel like we practiced a similar question where consent was a big issue, but I can't recall if age really matters here. Option C seems off to me.
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Pearly
5 months ago
I'm not entirely sure, but I remember something about local legislation possibly allowing for exceptions. Maybe option B is the right choice?
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Jesusita
5 months ago
I think option A sounds familiar, like something we discussed about balancing effort and rights in our privacy law class.
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