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| Section | Objectives |
|---|---|
| Topic 1: Sustaining Program Performance | - Implement continuous improvement - Measure program effectiveness - Monitor and audit privacy program |
| Topic 2: Assessing Data | - Perform privacy impact assessments - Manage vendor and third-party risks - Conduct data inventory and mapping |
| Topic 3: Establishing Governance | - Define roles and responsibilities - Establish reporting mechanisms - Create privacy policies and procedures |
| Topic 4: Developing a Framework | - Define program scope and stakeholders - Establish privacy governance structure - Identify applicable laws and frameworks |
| Topic 5: Responding to Requests and Incidents | - Coordinate with regulators - Handle data subject requests - Manage data breaches and incidents |
| Topic 6: Protecting Personal Data | - Manage data subject rights - Implement privacy and security controls - Handle cross-border data transfers |
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NEW QUESTION # 107
SCENARIO
Please use the following to answer the next QUESTION:
Natalia, CFO of the Nationwide Grill restaurant chain, had never seen her fellow executives so anxious. Last week, a data processing firm used by the company reported that its system may have been hacked, and customer data such as names, addresses, and birthdays may have been compromised. Although the attempt was proven unsuccessful, the scare has prompted several Nationwide Grill executives to Question the company's privacy program at today's meeting.
Alice, a vice president, said that the incident could have opened the door to lawsuits, potentially damaging Nationwide Grill's market position. The Chief Information Officer (CIO), Brendan, tried to assure her that even if there had been an actual breach, the chances of a successful suit against the company were slim. But Alice remained unconvinced.
Spencer - a former CEO and currently a senior advisor - said that he had always warned against the use of contractors for data processing. At the very least, he argued, they should be held contractually liable for telling customers about any security incidents. In his view, Nationwide Grill should not be forced to soil the company name for a problem it did not cause.
One of the business development (BD) executives, Haley, then spoke, imploring everyone to see reason.
"Breaches can happen, despite organizations' best efforts," she remarked. "Reasonable preparedness is key." She reminded everyone of the incident seven years ago when the large grocery chain Tinkerton's had its financial information compromised after a large order of Nationwide Grill frozen dinners. As a long-time BD executive with a solid understanding of Tinkerton's's corporate culture, built up through many years of cultivating relationships, Haley was able to successfully manage the company's incident response.
Spencer replied that acting with reason means allowing security to be handled by the security functions within the company - not BD staff. In a similar way, he said, Human Resources (HR) needs to do a better job training employees to prevent incidents. He pointed out that Nationwide Grill employees are overwhelmed with posters, emails, and memos from both HR and the ethics department related to the company's privacy program. Both the volume and the duplication of information means that it is often ignored altogether.
Spencer said, "The company needs to dedicate itself to its privacy program and set regular in-person trainings for all staff once a month." Alice responded that the suggestion, while well-meaning, is not practical. With many locations, local HR departments need to have flexibility with their training schedules. Silently, Natalia agreed.
How could the objection to Spencer's training suggestion be addressed?
Answer: A
Explanation:
Explanation
This answer is the best way to address the objection to Spencer's training suggestion, as it can provide flexibility and convenience for employees who work in different locations or have different schedules.
Alternative delivery methods for trainings can include online courses, webinars, podcasts, videos or self-paced modules that can be accessed anytime and anywhere by employees. Alternative delivery methods can also reduce the cost and time required for in-person trainings, while still ensuring that employees receive consistent and relevant information on the company's privacy program. References: IAPP CIPM Study Guide, page 90; ISO/IEC 27002:2013, section 7.2.2
NEW QUESTION # 108
An organization's privacy officer was just notified by the benefits manager that she accidentally sent out the retirement enrollment report of all employees to a wrong vendor. Which of the following actions should the privacy officer take FIRST?
Answer: A
NEW QUESTION # 109
In addition to regulatory requirements and business practices, what important factors must a global privacy strategy consider?
Answer: A
Explanation:
In addition to regulatory requirements and business practices, an important factor that a global privacy strategy must consider is cultural norms. Different cultures may have different expectations and preferences regarding privacy, such as what constitutes personal information, how consent is obtained and expressed, how data is used and shared, and how privacy rights are enforced. A global privacy strategy should respect and accommodate these cultural differences and ensure that the organization's privacy practices are transparent, fair, and consistent across different regions. Reference: [IAPP CIPM Study Guide], page 81-82; [Cultural Differences in Privacy Expectations]
NEW QUESTION # 110
SCENARIO
Please use the following to answer the next QUESTION:
As the Director of data protection for Consolidated Records Corporation, you are justifiably pleased with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of relatively minor data breaches that could easily have been worse. However, you have not had a reportable incident for the three years that you have been with the company. In fact, you consider your program a model that others in the data storage industry may note in their own program development.
You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward coherence across departments and throughout operations. You were aided along the way by the program's sponsor, the vice president of operations, as well as by a Privacy Team that started from a clear understanding of the need for change.
Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard" among both the executive team and frontline personnel working with data and interfacing with clients. Through the use of metrics that showed the costs not only of the breaches that had occurred, but also projections of the costs that easily could occur given the current state of operations, you soon had the leaders and key decision-makers largely on your side. Many of the other employees were more resistant, but face-to-face meetings with each department and the development of a baseline privacy training program achieved sufficient "buy-in" to begin putting the proper procedures into place.
Now, privacy protection is an accepted component of all current operations involving personal or protected data and must be part of the end product of any process of technological development. While your approach is not systematic, it is fairly effective.
You are left contemplating:
What must be done to maintain the program and develop it beyond just a data breach prevention program? How can you build on your success?
What are the next action steps?
What process could most effectively be used to add privacy protections to a new, comprehensive program being developed at Consolidated?
Answer: C
Explanation:
This is a process that embeds privacy protections into the design and development of new technologies, systems, products or services that involve personal data. It ensures that privacy is considered at every stage of the development process, from conception to completion, and that the privacy principles are integrated into the core functionality of the program.
NEW QUESTION # 111
SCENARIO
Please use the following to answer the next QUESTION:
As the Director of data protection for Consolidated Records Corporation, you are justifiably pleased with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of relatively minor data breaches that could easily have been worse. However, you have not had a reportable incident for the three years that you have been with the company. In fact, you consider your program a model that others in the data storage industry may note in their own program development.
You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward coherence across departments and throughout operations. You were aided along the way by the program's sponsor, the vice president of operations, as well as by a Privacy Team that started from a clear understanding of the need for change.
Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard" among both the executive team and frontline personnel working with data and interfacing with clients. Through the use of metrics that showed the costs not only of the breaches that had occurred, but also projections of the costs that easily could occur given the current state of operations, you soon had the leaders and key decision-makers largely on your side. Many of the other employees were more resistant, but face-to-face meetings with each department and the development of a baseline privacy training program achieved sufficient "buy-in" to begin putting the proper procedures into place.
Now, privacy protection is an accepted component of all current operations involving personal or protected data and must be part of the end product of any process of technological development. While your approach is not systematic, it is fairly effective.
You are left contemplating:
What must be done to maintain the program and develop it beyond just a data breach prevention program? How can you build on your success?
What are the next action steps?
Which of the following would be most effectively used as a guide to a systems approach to implementing data protection?
Answer: B
Explanation:
This series of standards provides a framework for establishing, implementing, maintaining and improving an information security management system (ISMS), which includes data protection as a key component.
NEW QUESTION # 112
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