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IAPP CIPP/E Exam - Topic 4 Question 112 Discussion

Posted by Arminda on Aug 16, 2025 at 07:58 PM

Which aspect of processing does the GDPR allow processors to determine for themselves?

Suggested Answer: D

The GDPR defines processors as entities that process personal data on behalf of controllers, typically under a contract or other legal act that sets out the subject matter, duration, nature, purpose, type and categories of personal data, and the obligations and rights of the controller. Processors must act only on the documented instructions of the controller, unless required by law to act otherwise. Processors must also comply with the GDPR's requirements regarding the security, confidentiality, transfer, sub-processing, notification, assistance, cooperation, and documentation of the personal data processing.

However, the GDPR does not prescribe the exact technical and organisational measures that processors must implement to ensure the security of the personal data processing. Instead, the GDPR requires that processors take into account the state of the art, the costs of implementation, the nature, scope, context and purposes of the processing, and the risks for the rights and freedoms of data subjects. Therefore, processors have some discretion to determine their own type of hardware or software and the specific security measures for the processing, as long as they provide a level of security appropriate to the risk and comply with the controller's instructions. Processors may also adhere to approved codes of conduct or certification mechanisms to demonstrate their compliance with the GDPR's security requirements.

The other options listed in the question are not aspects of processing that the GDPR allows processors to determine for themselves. According to the GDPR:

Processors must inform the controller of any intended changes concerning the addition or replacement of other processors, and give the controller the opportunity to object to such changes. Processors must also impose the same data protection obligations on any sub-processors as those agreed with the controller.

Processors must not process the personal data for their own purposes, unless they have a legal basis to do so and inform the data subjects accordingly. Processors must only process the personal data for the purposes determined by the controller, and in accordance with the controller's instructions.

Processors must not use the personal data relating to the controller's customers for their own marketing campaigns, unless they have obtained the consent of the data subjects or have another legitimate interest to do so. Processors must respect the data subjects' rights to object to direct marketing and to withdraw their consent at any time.


GDPR, Articles 4, 28, 29, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42 and 43.

EDPB Guidelines 07/2020 on the concepts of controller and processor in the GDPR, pages 19, 20, 21, 22, 23, 24, 25, 26, 27 and 28.

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17 comments · newest first
MA
Maryann 11 months ago
Not so sure about that, isn't it more about A?
PA
Patrick 11 months ago
Totally agree, B makes the most sense here.
YO
Yoko 11 months ago
Wow, I didn't realize they could choose their own hardware too!
SV
Svetlana 11 months ago
Wait, can they really decide on security measures? Sounds risky!
AN
Andrew 11 months ago
I think it's B! They can set their own purposes.
ME
Merilyn 12 months ago
I think it's definitely about the parameters of their marketing campaigns, but I need to double-check if that's what the GDPR actually allows.
PA
Pamela 12 months ago
I feel like the answer might be related to how they can use personal data for their own purposes, but I could be mixing it up with another topic.
SH
Sharen 1 year ago
I remember a practice question about processors determining their own security measures, but I can't recall if that's the right answer here.
EL
Eloisa 1 year ago
I think the GDPR gives processors some leeway, but I'm not sure if it's about their own purposes or just the security measures.
JO
Johnathon 1 year ago
Okay, I've got a strategy - I'll eliminate the options that are clearly not correct, then carefully consider the remaining choices.
SE
Selma 1 year ago
I think the answer is B. The GDPR allows processors to determine their own purposes for processing, as long as they're compatible with the original purpose.
BR
Brandon 1 year ago
Hmm, I'm not totally sure about this. I'll have to review the GDPR guidelines on processor responsibilities again before answering.
VA
Valene 1 year ago
This seems like a tricky one. I'll need to really focus on the key details in the GDPR to figure this out.
PA
Paris 1 year ago
B seems like the obvious choice here. I mean, who wouldn't want to determine their own purposes for processing data? Gotta keep those marketing campaigns juicy, am I right?
MY
My 1 year ago
But what about option D? Doesn't that also give processors some control?
GO
Golda 1 year ago
I agree with Jenelle, processors can determine their own purposes for processing.
JE
Jenelle 1 year ago
I think the answer is B.
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