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| Section | Objectives |
|---|---|
| Responding to Requests and Incidents | - Coordinate with regulators - Handle data subject requests - Manage data breaches and incidents |
| Assessing Data | - Perform privacy impact assessments - Conduct data inventory and mapping - Manage vendor and third-party risks |
| Developing a Framework | - Define program scope and stakeholders - Establish privacy governance structure - Identify applicable laws and frameworks |
| Sustaining Program Performance | - Measure program effectiveness - Implement continuous improvement - Monitor and audit privacy program |
| Establishing Governance | - Create privacy policies and procedures - Establish reporting mechanisms - Define roles and responsibilities |
| Protecting Personal Data | - Handle cross-border data transfers - Implement privacy and security controls - Manage data subject rights |
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NEW QUESTION # 205
SCENARIO
Please use the following to answer the next QUESTION:
It's just what you were afraid of. Without consulting you, the information technology director at your organization launched a new initiative to encourage employees to use personal devices for conducting business. The initiative made purchasing a new, high-specification laptop computer an attractive option, with discounted laptops paid for as a payroll deduction spread over a year of paychecks. The organization is also paying the sales taxes. It's a great deal, and after a month, more than half the organization's employees have signed on and acquired new laptops. Walking through the facility, you see them happily customizing and comparing notes on their new computers, and at the end of the day, most take their laptops with them, potentially carrying personal data to their homes or other unknown locations. It's enough to give you data- protection nightmares, and you've pointed out to the information technology Director and many others in the organization the potential hazards of this new practice, including the inevitability of eventual data loss or theft.
Today you have in your office a representative of the organization's marketing department who shares with you, reluctantly, a story with potentially serious consequences. The night before, straight from work, with laptop in hand, he went to the Bull and Horn Pub to play billiards with his friends. A fine night of sport and socializing began, with the laptop "safely" tucked on a bench, beneath his jacket. Later that night, when it was time to depart, he retrieved the jacket, but the laptop was gone. It was not beneath the bench or on another bench nearby. The waitstaff had not seen it. His friends were not playing a joke on him. After a sleepless night, he confirmed it this morning, stopping by the pub to talk to the cleanup crew. They had not found it.
The laptop was missing. Stolen, it seems. He looks at you, embarrassed and upset.
You ask him if the laptop contains any personal data from clients, and, sadly, he nods his head, yes. He believes it contains files on about 100 clients, including names, addresses and governmental identification numbers. He sighs and places his head in his hands in despair.
In order to determine the best course of action, how should this incident most productively be viewed?
Answer: A
Explanation:
This answer recognizes the risk of data breach that may result from the loss of the laptop, as it may expose the personal information of the clients to unauthorized or unlawful processing. A data breach is defined as a security incident that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed. A data breach may have serious consequences for the individuals whose data is compromised, such as identity theft, fraud, discrimination, financial loss or reputational damage. Therefore, it is important to view this incident as a potential compromise of personal information and take appropriate measures to contain, assess and mitigate the impact of the breach. References: IAPP CIPM Study Guide, page 86; ISO/IEC 27002:2013, section 16.1.1
NEW QUESTION # 206
SCENARIO
Please use the following to answer the next QUESTION:
Perhaps Jack Kelly should have stayed in the U.S. He enjoys a formidable reputation inside the company, Special Handling Shipping, for his work in reforming certain "rogue" offices. Last year, news broke that a police sting operation had revealed a drug ring operating in the Providence, Rhode Island office in the United States. Video from the office's video surveillance cameras leaked to news operations showed a drug exchange between Special Handling staff and undercover officers.
In the wake of this incident, Kelly had been sent to Providence to change the "hands off" culture that upper management believed had let the criminal elements conduct their illicit transactions. After a few weeks under Kelly's direction, the office became a model of efficiency and customer service. Kelly monitored his workers' activities using the same cameras that had recorded the illegal conduct of their former co-workers.
Now Kelly has been charged with turning around the office in Cork, Ireland, another trouble spot. The company has received numerous reports of the staff leaving the office unattended. When Kelly arrived, he found that even when present, the staff often spent their days socializing or conducting personal business on their mobile phones. Again, he observed their behaviors using surveillance cameras. He issued written reprimands to six staff members based on the first day of video alone.
Much to Kelly's surprise and chagrin, he and the company are now under investigation by the Data Protection Commissioner of Ireland for allegedly violating the privacy rights of employees. Kelly was told that the company's license for the cameras listed facility security as their main use, but he does not know why this matters. He has pointed out to his superiors that the company's training programs on privacy protection and data collection mention nothing about surveillance video.
You are a privacy protection consultant, hired by the company to assess this incident, report on the legal and compliance issues, and recommend next steps.
What does this example best illustrate about training requirements for privacy protection?
Answer: B
NEW QUESTION # 207
What have experts identified as an important trend in privacy program development?
Answer: D
Explanation:
An important trend in privacy program development is the movement beyond crisis management to proactive prevention. This means that instead of reacting to privacy breaches or incidents after they occur, organizations are taking steps to prevent them from happening in the first place. This involves implementing privacy by design principles, conducting privacy impact assessments, adopting privacy-enhancing technologies, training staff on privacy awareness and best practices, and monitoring compliance and performance. By doing so, organizations can reduce risks, costs, and reputational damage associated with privacy violations. Reference: [IAPP CIPM Study Guide], page 93-94; [Moving from Crisis Management to Proactive Prevention]
NEW QUESTION # 208
Under the General Data Protection Regulation (GDPR), which of the following situations would LEAST likely require a controller to notify a data subject?
Answer: C
Explanation:
Under the GDPR, a controller must notify a data subject of a personal data breach without undue delay when the breach is likely to result in a high risk to the rights and freedoms of the data subject, unless one of the following conditions applies: the personal data are rendered unintelligible to any person who is not authorized to access it, such as by encryption; the controller has taken subsequent measures to ensure that the high risk is no longer likely to materialize; or the notification would involve disproportionate effort, in which case a public communication or similar measure may suffice. In this case, an encrypted USB key with sensitive personal data is stolen, but the personal data are presumably unintelligible to the thief, so the controller does not need to notify the data subject. However, the controller still needs to notify the supervisory authority within 72 hours of becoming aware of the breach, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons.
Reference:
CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section B: Protecting Personal Information, Subsection 2: Data Breach Incident Planning and Management CIPM Study Guide (2021), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management CIPM Textbook (2019), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management CIPM Practice Exam (2021), Question 134 GDPR Article 33 and 3412
NEW QUESTION # 209
SCENARIO
Please use the following to answer the next QUESTION:
Edufox has hosted an annual convention of users of its famous e-learning software platform, and over time, it has become a grand event. It fills one of the large downtown conference hotels and overflows into the others, with several thousand attendees enjoying three days of presentations, panel discussions and networking. The convention is the centerpiece of the company's product rollout schedule and a great training opportunity for current users. The sales force also encourages prospective clients to attend to get a better sense of the ways in which the system can be customized to meet diverse needs and understand that when they buy into this system, they are joining a community that feels like family.
This year's conference is only three weeks away, and you have just heard news of a new initiative supporting it: a smartphone app for attendees. The app will support late registration, highlight the featured presentations and provide a mobile version of the conference program. It also links to a restaurant reservation system with the best cuisine in the areas featured. "It's going to be great," the developer, Deidre Hoffman, tells you, "if, that is, we actually get it working!" She laughs nervously but explains that because of the tight time frame she'd been given to build the app, she outsourced the job to a local firm. "It's just three young people," she says, "but they do great work." She describes some of the other apps they have built. When asked how they were selected for this job, Deidre shrugs. "They do good work, so I chose them." Deidre is a terrific employee with a strong track record. That's why she's been charged to deliver this rushed project. You're sure she has the best interests of the company at heart, and you don't doubt that she's under pressure to meet a deadline that cannot be pushed back. However, you have concerns about the app's handling of personal data and its security safeguards. Over lunch in the break room, you start to talk to her about it, but she quickly tries to reassure you, "I'm sure with your help we can fix any security issues if we have to, but I doubt there'll be any. These people build apps for a living, and they know what they're doing. You worry too much, but that's why you're so good at your job!" You see evidence that company employees routinely circumvent the privacy officer in developing new initiatives.
How can you best draw attention to the scope of this problem?
Answer: B
NEW QUESTION # 210
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