CIPP-E Exam Dumps | Through a combination of hardware failure and human error, the decryption key for a bank's customer account

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IAPP.CIPP-E.v2025-08-16.q131
Question 40

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Question 40/131

Through a combination of hardware failure and human error, the decryption key for a bank's customer account transaction database has been lost. An investigation has determined that this was not the result of hacking or malfeasance, simply an unfortunate combination of circumstances. Which of the following accurately indicates the nature of this incident?

A. A data breach has not occurred because the loss was not the result of hacking.

B. A data breach has not occurred because no data was exposed to any unauthorized individual.

C. A data breach has occurred because the loss of the key has resulted in the data no longer being accessible.

D. A data breach has occurred because the loss of the key has resulted in the loss of confidentiality or integrity of the data.

Correct Answer: D

A data breach is broadly defined as any incident that leads to the unauthorized access, disclosure, alteration, or destruction of personal data. While options A and B might seem plausible at first glance, they focus on a narrow interpretation of a breach.
The key here is the loss of confidentiality and/or integrity. Even though no one has actively stolen the data, the bank can no longer guarantee the confidentiality of the information, nor can it ensure the integrity of the data since it cannot be accessed or modified securely. This constitutes a loss of control over the data and thus qualifies as a data breach.
Reference:
IAPP CIPP/E textbook, Chapter 5: Data Breach Notification (specifically, the definition of a personal data breach) GDPR Article 4(12) - Definition of a personal data breach

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