ICS ECDPO Practice Questions - European Certified Data Protection Officer (ICS ADPO, Ireland) Exam

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A Galway hospital processes patient health records as its primary activity. Which mandatory DPO designation ground applies?

Article 37(1)(b) only — hospitals are never special category processors. Core activities consisting of large-scale processing of special category data under Article 9 (Article 37(1)(c)). No mandatory designation — healthcare relies on implied consent instead. Article 37(1)(a) only if the hospital is a private company.

Correct Answer:

Core activities consisting of large-scale processing of special category data under Article 9 (Article 37(1)(c)).

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