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IAPP CIPP-E Exam - Topic 5 Question 122 Discussion

Which of the following describes a mandatory requirement for a group of undertakings that wants to appoint a single data protection officer?
D) The data protection officer must be easily accessible from each establishment where the undertakings are located.
A) The group of undertakings must obtain approval from a supervisory authority.
B) The group of undertakings must be comprised of organizations of similar sizes and functions.
C) The data protection officer must be located in the country where the data controller has its main establishment.

IAPP CIPP-E Exam - Topic 5 Question 122 Discussion

Actual exam question for IAPP's CIPP-E exam
Question #: 122
Topic #: 5
[All CIPP-E Questions]

Which of the following describes a mandatory requirement for a group of undertakings that wants to appoint a single data protection officer?

Show Suggested Answer Hide Answer
Suggested Answer: D

According to Article 37(2) of the GDPR, a group of undertakings may appoint a single data protection officer (DPO) provided that the DPO is easily accessible from each establishment12.This means that the DPO should be able to communicate effectively with the data subjects and the supervisory authorities in the relevant languages and jurisdictions, and to perform the tasks referred to in Article 39 of the GDPR34.The accessibility of the DPO does not necessarily depend on the physical location of the DPO, but rather on the availability of the DPO to the relevant stakeholders via various means of communication34. Therefore, the DPO does not have to be located in the country where the data controller has its main establishment, nor does the group of undertakings have to obtain approval from a supervisory authority or be comprised of organizations of similar sizes and functions to appoint a single DPO.Reference:CIPP/E Certification - International Association of Privacy Professionals,Free CIPP/E Study Guide - International Association of Privacy Professionals,GDPR - EUR-Lex,What's different about a group data protection officer?,Data Protection Officers: What US Companies Need to Know - Cooley


by Elvera at May 11, 2026, 12:52 PM

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Jeannine
True, but D is more practical. They need to be there for all locations.
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Long
5 days ago
But what about A? Approval from a supervisory authority seems important too.
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Tammara
10 days ago
I agree, D makes sense. The DPO needs to be reachable.
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Marge
15 days ago
I think option D is key. Accessibility is crucial for compliance.
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Lynsey
20 days ago
Wait, are you sure about the location requirement? Seems odd!
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Jade
26 days ago
That sounds right, but what if the organizations are different sizes?
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Gaynell
1 month ago
Actually, I heard they don't need supervisory approval.
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Nana
1 month ago
I think they also need to be in the main establishment's country.
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Christiane
1 month ago
A single DPO needs to be accessible from all locations.
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Lindsey
2 months ago
Wait, are you sure about D? Sounds too vague!
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Cheryl
2 months ago
B makes sense, but not always practical.
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Melvin
2 months ago
C seems a bit strict, doesn't it?
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Ruthann
2 months ago
I thought A was necessary too, but I guess not?
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Carla
2 months ago
D is definitely a must-have for accessibility!
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Devorah
2 months ago
I remember that the DPO needs to be accessible, so D sounds right, but I also have a nagging feeling about the requirements for the group itself.
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Jamal
3 months ago
I'm leaning towards A because I recall discussing the need for approval from authorities in some cases, but I could be mixing it up with another topic.
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Cyril
3 months ago
I feel like we covered a similar question in class, and I think it was about the location of the DPO. So maybe it's C?
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Susana
4 months ago
I think the answer might be D, but I'm not completely sure. I remember something about accessibility being important for DPOs.
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