CIPP-C IAPP Certified Information Privacy Professional/ Canada (CIPP/C) Free Practice Exam Questions (2025 Updated)

"Hashing" is preferable to storing a personal identifier, such as a driver’s license number, because it still provides a method for customer identification but in a form that would not reveal the real number. Hashing is a security technique that converts data into a fixed-size string of characters, which is typically a hash code. The hash code represents the original data but does not allow it to be reconstructed or decrypted. In the context of data security, hashing is valuable because it protects sensitive personal identifiers from exposure while still enabling the organization to verify or match the hashed data with incoming hashed inputs for identification purposes.

In addressing emerging AI issues, frameworks that are specific to product safety, copyright, or criminal behavior may provide some indirect governance, but their applicability is limited compared to more direct regulatory mechanisms. Among the options listed, the Motor Vehicle Safety Act is the least effective in addressing AI issues as this act is specifically targeted towards the safety regulations of motor vehicles and is less applicable to broader AI issues that may involve data privacy, ethical considerations, and other non-vehicle-specific technologies. Therefore, while AI can be involved in vehicle safety, this act is less equipped to broadly address emerging AI issues beyond automotive safety standards. Hence, the correct answer is B, "The Motor Vehicle Safety Act."

Under the Privacy Act, which governs the handling of personal information by federal government institutions, the Privacy Commissioner of Canada does not have the authority to order institutions to take remedial action. The Commissioner's powers are limited to investigating complaints, making recommendations, and, where necessary, taking matters to the Federal Court for resolution. While the Commissioner can recommend solutions and proceed to court to seek orders for compliance, direct enforcement powers, such as ordering remedial actions independently, are not granted under the Privacy Act. Thus, the correct answer is B.

Under the Personal Information Protection and Electronic Documents Act (PIPEDA), express consent is not required when the personal information is publicly available as defined by the regulation. According to the regulations specifying publicly available information under PIPEDA, certain types of information, like that published in directories or records where the individual has provided the information for public dissemination, are excluded from the consent requirement. This provision is aimed at balancing the need for privacy protection with the practicalities of information that has been intentionally made public by the individual or by legal requirement. The other options listed (A, C, D) generally require express consent as they involve uses of personal information that either extend beyond what the individual would reasonably expect, or change the context in which the information was originally collected.

The Office of the Privacy Commissioner of Canada’s (OPC) four-point test for determining the necessity and reasonableness of collecting, using, or disclosing personal information does not include questioning the validity and accuracy of the information as a direct component. The four-point test includes examining whether the measure is necessary to meet a specific need; whether it is likely to be effective in meeting that need; whether the loss of privacy is proportional to the benefit gained; and whether there are less privacy-invasive ways to achieve the same end. Therefore, option C, "Are the validity and accuracy of individual test results guaranteed to be accurate?" is not part of this test, as it concerns the technical and scientific reliability of the tests rather than the privacy implications of accessing or sharing the results.

Before implementing an electronic service (e-service), a federal government department is required to complete a Privacy Impact Assessment (PIA) in accordance with Treasury Board guidelines. A PIA is a process that helps federal institutions to evaluate how new or substantially modified programs or services could affect individual privacy and to address those effects appropriately. The guidelines provided by the Treasury Board specify how PIAs should be conducted to ensure that all privacy risks are identified and mitigated before the implementation of a new or modified e-service. This requirement is crucial for maintaining the privacy and security of personal information handled by government departments.

Before an individual requester can commence a court application relating to the denial of access to personal information under the control of a federal government institution, the Privacy Commissioner of Canada must have completed an investigation and issued a report. This procedural step is crucial because it ensures that the administrative avenues for resolving access disputes are exhausted before judicial intervention is sought. The Privacy Commissioner's report may provide findings and recommendations that could resolve the matter without the need for court proceedings, or it might clarify the issues and the reasons behind the denial, thereby informing any subsequent legal challenges.

The case of Abika.com was significant in establishing the jurisdiction of the Office of the Privacy Commissioner of Canada (OPC) over foreign entities processing personal data of Canadians. In this case, the Federal Court ruled that the OPC had the authority to investigate complaints about a US-based company, Abika.com, which was collecting, using, and disclosing the personal information of individuals in Canada for background checks. This case helped to affirm the OPC's role in overseeing how Canadian citizens' personal information is handled by companies, regardless of their geographic location, ensuring that the privacy rights of Canadians are respected by foreign operators engaging with Canadian data subjects.

The main reason a country might adopt an "ombudsman" model of privacy oversight is to reduce the perception that compliance is a confrontational process. The ombudsman model focuses on mediation and resolution rather than enforcement, aiming to resolve issues through dialogue and negotiation rather than punitive measures. This approach helps to foster a cooperative relationship between the regulator and the entities they oversee, which can lead to more effective compliance and less adversarial interactions. This model contrasts with more regulatory or enforcement-driven models, which might focus on sanctions and formal adjudications.

Translating the hotel's registration page into German based on the visitor's IP address is most likely to result in a finding that the boutique hotel in Montreal is subject to the General Data Protection Regulation (GDPR). This action could be interpreted as targeting European Union residents specifically, thereby bringing the hotel’s activities within the scope of the GDPR. Actions like language customization based on geographic location explicitly target individuals within the EU, demonstrating intent to offer services directly to these consumers, a key criterion for GDPR applicability.

Under the Privacy Act, government institutions are typically allowed to disclose personal information without the consent of the individual in certain circumstances, such as for law enforcement purposes or in compliance with court orders (e.g., search warrants). Disclosures to a member of parliament to assist in resolving a problem also usually do not require consent if they are for a purpose consistent with the reason the data was initially collected. However, disclosing personal information to a registered charitable organization would not fall under these usual exceptions and would generally require the individual's consent unless another specific exception applies. This ensures that personal information is not shared beyond the scope of its original collection purpose without appropriate authorization.

The role of Canadian courts in reviewing decisions made by provincial oversight authorities generally involves examining whether there have been specific types of errors in the decision-making process, such as a misinterpretation of a term in the legislation or application of the law. This judicial review focuses on the legality and reasonableness of the decisions, ensuring that oversight authorities correctly interpret and apply the legislative framework governing privacy and data protection. This review does not extend to re-evaluating all investigative notes or comparing decisions across different provincial authorities, as such tasks are beyond the scope of a typical judicial review process. Therefore, Option C correctly describes the court's role.

Under the Personal Information Protection and Electronic Documents Act (PIPEDA), there are specific circumstances where a commercial business in Canada is allowed to collect personal information without the knowledge or consent of the individual1. These exceptions include:

Journalistic or literary purposes (option A): Organizations may collect personal information without consent when it’s for journalistic, artistic, or literary purposes, as these activities are considered to fall under the freedom of expression provisions.

Interests of the individual (option B): If the collection is clearly in the interests of the individual and consent cannot be obtained in a timely way, for example in emergency situations where the individual’s life, health, or security is threatened.

Investigative purposes (option D): When the collection with the knowledge of the individual would compromise the availability or accuracy of the information, and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.

However, option C is not one of the exceptions provided under PIPEDA. The act does not allow for the collection of personal information without consent solely on the basis that the collection would lead to the creation of products that would benefit the public and consent would be difficult to obtain. While public benefit is a consideration in the ethical use of personal information, it does not override the requirement for consent under PIPEDA unless the situation falls under other specific exceptions1.

Therefore, the correct answer is C, as it is the exception that is not permitted under the current framework of PIPEDA for collecting personal information without the knowledge or consent of the individual1.

Oversight authorities generally allow various forms of consent including implied consent, verbal consent, and written consent specific to the purpose for which the information is collected. However, they do not typically accept a "general consent" that covers all activities associated with the personal information. Consent must be specific and informed, clearly relating to the particular context in which personal information is to be used or disclosed. General consent fails to meet the specificity required under privacy laws like PIPEDA, which necessitates that consent be explicit for particularly sensitive information or whenever there is a significant change in the use of the information.

The key difference between the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Personal Information Privacy Act (PIPA) of both Alberta and British Columbia is the scope of their application. PIPEDA applies to federal undertakings and to organizations that engage in commercial activities across provincial or national borders, thus under federal jurisdiction. In contrast, PIPA legislation in Alberta and British Columbia applies only to private organizations within those provinces, covering most commercial activities that do not cross provincial boundaries unless otherwise covered under federal law. This distinction highlights the division of legislative powers between federal and provincial levels concerning privacy regulation in Canada.

When a financial institution such as a bank or an investment advisor collects a social insurance number (SIN) for tax reporting purposes, especially in contexts like opening a Registered Retirement Savings Plan (RRSP), it is mandatory because the SIN is required by law for such purposes. However, the use of the SIN for other purposes, such as identity verification, is not mandatory and should only be done with the client's consent. Thus, the correct answer is A, "Optional for identity verification purposes," indicating that while the SIN is necessary for tax purposes, its use for verifying identity is at the client's discretion.

Under the Personal Information Protection and Electronic Documents Act (PIPEDA), certain types of data are considered particularly sensitive due to the potential for harm if misused or disclosed. This includes information about an individual's physical disability, ethnicity, sexual orientation, and religion. Religion, as a category of sensitive information, can reveal deeply personal beliefs and affiliations that, if mishandled, could lead to discrimination or other adverse effects. PIPEDA recognizes that sensitive information requires a higher level of protection and generally mandates that explicit consent is obtained before such information is collected, used, or disclosed.

When conducting surveys that collect personal information, it is crucial to protect the privacy of the respondents. The best practice, according to CIPP/C guidelines, is to collect results anonymously whenever possible1. This can be achieved by using pseudonyms to identify employees, which aligns with the option A. This method allows the company to analyze the data without exposing the personal identities of the employees.

Using a survey tool located in Canada (option B) may not necessarily protect the personal information unless the tool itself has robust privacy features that comply with Canadian privacy laws. Encryption (option C) is a strong method to secure data but does not address the issue of anonymity in the data collection process. Adjusting the survey questions to not collect identifying information (option D) could potentially undermine the purpose of the DEI initiatives, as some demographic information may be necessary for analysis.

The International Association of Privacy Professionals (IAPP) provides a global standard for privacy laws, regulations, and frameworks, which includes the protection of personal information in surveys. The CIPP/C certification ensures that professionals understand these principles and practices within the Canadian context2. The guidelines suggest that when personal information is collected, it should be done in a way that respects the privacy of individuals, which includes minimizing the risk of identification3.

In conclusion, using pseudonyms is the best solution among the given options to protect personal information while still allowing the company to invest in DEI initiatives and gather the necessary data for analysis. This approach is in line with the principles-based framework and knowledge base in information privacy as outlined by the CIPP/C certification program2.

From the Blood Tribe case, it can be concluded that the Privacy Commissioner of Canada can officially request proof that the information sought in an investigation is subject to solicitor-client privilege. The Supreme Court of Canada held in this case that while the Commissioner has significant investigative powers, these do not automatically override the solicitor-client privilege. The decision clarifies that any organization claiming such a privilege must substantiate its claim, and the Commissioner has the authority to challenge and request proof of this claim, ensuring the privilege is not used improperly to withhold information.