IAPP Certified Information Privacy Professional CIPP-E Question # 83 Topic 9 Discussion

According to the CIPP/E study guide, data controllers should use the least intrusive means of verifying the identity of data subjects who make requests under the GDPR. Asking for a copy of an ID document or a bank account statement may be disproportionate and excessive, as they contain more personal data than necessary for authentication. Asking for the bank account number may not be sufficient, as it may be easily obtained by third parties. Therefore, the most appropriate way to confirm the identity of the customer is to ask additional security questions that only the customer would know, such as the date of the last transaction, the amount of the last deposit, or the name of the beneficiary of a recurring payment.

References: CIPP/E Study Guide, page 28; CIPP/E Textbook, page 136.