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PECB GDPR Exam - Topic 1 Question 22 Discussion

Scenario 3:COR Bank is an international banking group that operates in 31 countries. It was formed as the merger of two well-known investment banks in Germany. Their two main fields of business are retail and investment banking. COR Bank provides innovative solutions for services such as payments, cash management, savings, protection insurance, and real-estate services. COR Bank has a large number of clients and transactions. Therefore, they process large information, including clients' personal data. Some of the data from the application processes of COR Bank, including archived data, is operated by Tibko, an IT services company located in Canada. To ensure compliance with the GDPR, COR Bank and Tibko have reached a data processing agreement Based on the agreement, the purpose and conditions of data processing are determined by COR Bank. However, Tibko is allowed to make technical decisions for storing the data based on its own expertise. COR Bank aims to remain a trustworthy bank and a long-term partner for its clients. Therefore, they devote special attention to legal compliance. They started the implementation process of a GDPR compliance program in 2018. The first step was to analyze the existing resources and procedures. Lisa was appointed as the data protection officer (DPO). Being the information security manager of COR Bank for many years, Lisa had knowledge of the organization's core activities. She was previously involved in most of the processes related to information systems management and data protection. Lisa played a key role in achieving compliance to the GDPR by advising the company regarding data protection obligations and creating a data protection strategy. After obtaining evidence of the existing data protection policy, Lisa proposed to adapt the policy to specific requirements of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of departments. As the DPO, she had access to several departments, including HR and Accounting Department. This assured the organization that there was a continuous cooperation between them. The activities of some departments within COR Bank are closely related to data protection. Therefore, considering their expertise, Lisa was advised from the top management to take orders from the heads of those departments when taking decisions related to their field. Based on this scenario, answer the following Questio n:Questio n:According to scenario 3, Lisa was appointed as the Data Protection Officer (DPO) of COR Bank. Is this action in compliance with GDPR?
A) Yes, the DPO may be a staff member of the controller or processor or fulfill the tasks based on a service contract.
B) Yes, the DPO must be a staff member of the controller or processor in all cases when processing includes special categories of data.
C) No, an external DPO must be contracted when personal data is collected or processed by an organization that is not established in the European Union.
D) No, Lisa cannot be appointed as a DPO because she was already an information security officer.

PECB GDPR Exam - Topic 1 Question 22 Discussion

Actual exam question for PECB's GDPR exam
Question #: 22
Topic #: 1
[All GDPR Questions]

Scenario 3:

COR Bank is an international banking group that operates in 31 countries. It was formed as the merger of two well-known investment banks in Germany. Their two main fields of business are retail and investment banking. COR Bank provides innovative solutions for services such as payments, cash management, savings, protection insurance, and real-estate services. COR Bank has a large number of clients and transactions. Therefore, they process large information, including clients' personal dat

a. Some of the data from the application processes of COR Bank, including archived data, is operated by Tibko, an IT services company located in Canada. To ensure compliance with the GDPR, COR Bank and Tibko have reached a data processing agreement Based on the agreement, the purpose and conditions of data processing are determined by COR Bank. However, Tibko is allowed to make technical decisions for storing the data based on its own expertise. COR Bank aims to remain a trustworthy bank and a long-term partner for its clients. Therefore, they devote special attention to legal compliance. They started the implementation process of a GDPR compliance program in 2018. The first step was to analyze the existing resources and procedures. Lisa was appointed as the data protection officer (DPO). Being the information security manager of COR Bank for many years, Lisa had knowledge of the organization's core activities. She was previously involved in most of the processes related to information systems management and data protection. Lisa played a key role in achieving compliance to the GDPR by advising the company regarding data protection obligations and creating a data protection strategy. After obtaining evidence of the existing data protection policy, Lisa proposed to adapt the policy to specific requirements of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of GDPR. Then, Lisa implemented the updates of the policy within COR Bank. To ensure consistency between processes of different departments within the organization, Lisa has constantly communicated with all heads of departments. As the DPO, she had access to several departments, including HR and Accounting Department. This assured the organization that there was a continuous cooperation between them. The activities of some departments within COR Bank are closely related to data protection. Therefore, considering their expertise, Lisa was advised from the top management to take orders from the heads of those departments when taking decisions related to their field. Based on this scenario, answer the following Questio n:

Questio n:

According to scenario 3, Lisa was appointed as the Data Protection Officer (DPO) of COR Bank. Is this action in compliance with GDPR?

Show Suggested Answer Hide Answer
Suggested Answer: A

Under Article 37(6) of GDPR, the DPO can be an employee of the company or an external contractor. Lisa's appointment complies with GDPR because she is a staff member with data protection expertise.

Option A is correct because GDPR allows organizations to appoint an internal or external DPO.

Option B is incorrect because a DPO does not have to be an internal staff member even for special categories of data.

Option C is incorrect because a company can appoint an internal DPO even if it operates internationally.

Option D is incorrect because having another role does not disqualify someone from being a DPO, as long as there is no conflict of interest.


GDPR Article 37(6) (DPO may be an employee or external contractor)

Recital 97 (DPO qualifications and independence)

by Yolando at Aug 13, 2026, 10:19 PM

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Ernie
4 days ago
I’m a bit confused about the requirements for DPOs in relation to special categories of data. I thought that might apply here, but I can't recall the specifics.
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Brock
9 days ago
I think option A makes sense because it aligns with what we studied about the flexibility in appointing a DPO. It seems like Lisa has the right qualifications.
upvoted 0 times
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Mila
14 days ago
I remember that the DPO can be a staff member or an external contractor, but I’m not sure if Lisa's previous role as an information security officer affects her appointment.
upvoted 0 times
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