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| Section | Weight | Objectives |
|---|---|---|
| Operational Life Cycle of a Privacy Program | 50% | - Assessing privacy risks and impacts - Managing data inventory and data flows - Implementing privacy controls and procedures - Monitoring, auditing, and continuous improvement |
| Privacy Program Governance | 50% | - Policy development and implementation - Privacy program structure and governance models - Stakeholder engagement and communication - Metrics, reporting, and accountability |
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NEW QUESTION # 209
SCENARIO
Please use the following to answer the next question:
Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner, Anton, has found some degree of disorganization after touring the company headquarters. His uncle Henry has always focused on production - not data processing - and Anton is concerned. In several storage rooms, he has found paper files, disks, and old computers that appear to contain the personal data of current and former employees and customers. Anton knows that a single break-in could irrevocably damage the company's relationship with its loyal customers. He intends to set a goal of guaranteed zero loss of personal information.
To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of the company. However, Kenneth - his uncle's vice president and longtime confidante - wants to hold off on Anton's idea in favor of converting any paper records held at the company to electronic storage. Kenneth believes this process would only take one or two years. Anton likes this idea; he envisions a password- protected system that only he and Kenneth can access.
Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier, but it will simplify the management of the stored data. The heads of subsidiaries like the art gallery and kitchenware store down the street will be responsible for their own information management. Then, any unneeded subsidiary data still in Anton's possession can be destroyed within the next few years.
After learning of a recent security incident, Anton realizes that another crucial step will be notifying customers. Kenneth insists that two lost hard drives in Question not cause for concern; all of the data was encrypted and not sensitive in nature. Anton does not want to take any chances, however. He intends on sending notice letters to all employees and customers to be safe.
Anton must also check for compliance with all legislative, regulatory, and market requirements related to privacy protection. Kenneth oversaw the development of the company's online presence about ten years ago, but Anton is not confident about his understanding of recent online marketing laws. Anton is assigning another trusted employee with a law background the task of the compliance assessment. After a thorough analysis, Anton knows the company should be safe for another five years, at which time he can order another check.
Documentation of this analysis will show auditors due diligence.
Anton has started down a long road toward improved management of the company, but he knows the effort is worth it. Anton wants his uncle's legacy to continue for many years to come.
Which of Anton's plans for improving the data management of the company is most unachievable?
Answer: C
NEW QUESTION # 210
Which will best assist you in quickly identifying weaknesses in your network and storage?
Answer: D
NEW QUESTION # 211
Which of the following helps build trust with customers and stakeholders?
Answer: C
Explanation:
Providing a dedicated privacy space with the privacy policy, explanatory documents and operation frameworks helps build trust with customers and stakeholders. A dedicated privacy space is a section on an organization's website or app that provides clear and transparent information about how the organization processes personal information and respects data subject rights. It can include documents such as: a privacy policy that explains what personal information is collected, why it is collected, how it is used, who it is shared with, and how it is protected; explanatory documents that provide more details or examples of specific processing activities or scenarios; and operation frameworks that describe the procedures and mechanisms for data subject requests, complaints, inquiries, or feedback. A dedicated privacy space can help customers and stakeholders understand the organization's privacy practices, choices, and values, and enhance their confidence and trust.
Reference:
CIPM Body of Knowledge (2021), Domain II: Privacy Program Framework, Section A: Privacy Program Framework Components, Subsection 1: Privacy Policies CIPM Study Guide (2021), Chapter 4: Privacy Program Framework Components, Section 4.1: Privacy Policies CIPM Textbook (2019), Chapter 4: Privacy Program Framework Components, Section 4.1: Privacy Policies CIPM Practice Exam (2021), Question 140
NEW QUESTION # 212
SCENARIO
Please use the following to answer the next QUESTION:
You lead the privacy office for a company that handles information from individuals living in several countries throughout Europe and the Americas. You begin that morning's privacy review when a contracts officer sends you a message asking for a phone call. The message lacks clarity and detail, but you presume that data was lost.
When you contact the contracts officer, he tells you that he received a letter in the mail from a vendor stating that the vendor improperly shared information about your customers. He called the vendor and confirmed that your company recently surveyed exactly 2000 individuals about their most recent healthcare experience and sent those surveys to the vendor to transcribe it into a database, but the vendor forgot to encrypt the database as promised in the contract. As a result, the vendor has lost control of the data.
The vendor is extremely apologetic and offers to take responsibility for sending out the notifications. They tell you they set aside 2000 stamped postcards because that should reduce the time it takes to get the notice in the mail. One side is limited to their logo, but the other side is blank and they will accept whatever you want to write. You put their offer on hold and begin to develop the text around the space constraints. You are content to let the vendor's logo be associated with the notification.
The notification explains that your company recently hired a vendor to store information about their most recent experience at St. Sebastian Hospital's Clinic for Infectious Diseases. The vendor did not encrypt the information and no longer has control of it. All 2000 affected individuals are invited to sign-up for email notifications about their information. They simply need to go to your company's website and watch a quick advertisement, then provide their name, email address, and month and year of birth.
You email the incident-response council for their buy-in before 9 a.m. If anything goes wrong in this situation, you want to diffuse the blame across your colleagues. Over the next eight hours, everyone emails their comments back and forth. The consultant who leads the incident-response team notes that it is his first day with the company, but he has been in other industries for 45 years and will do his best. One of the three lawyers on the council causes the conversation to veer off course, but it eventually gets back on track. At the end of the day, they vote to proceed with the notification you wrote and use the vendor's postcards.
Shortly after the vendor mails the postcards, you learn the data was on a server that was stolen, and make the decision to have your company offer credit monitoring services. A quick internet search finds a credit monitoring company with a convincing name: Credit Under Lock and Key (CRUDLOK). Your sales rep has never handled a contract for 2000 people, but develops a proposal in about a day which says CRUDLOK will:
1.Send an enrollment invitation to everyone the day after the contract is signed.
2.Enroll someone with just their first name and the last-4 of their national identifier.
3.Monitor each enrollee's credit for two years from the date of enrollment.
4.Send a monthly email with their credit rating and offers for credit-related services at market rates.
5.Charge your company 20% of the cost of any credit restoration.
You execute the contract and the enrollment invitations are emailed to the 2000 individuals. Three days later you sit down and document all that went well and all that could have gone better. You put it in a file to reference the next time an incident occurs.
Regarding the notification, which of the following would be the greatest concern?
Answer: D
Explanation:
Explanation
This answer is the greatest concern regarding the notification, as it violates the data minimization principle and exposes the affected individuals to further privacy and security risks. Collecting more personally identifiable information than necessary to provide updates to the affected individuals means that the company is asking for their name, email address, and month and year of birth, which may not be relevant or proportionate for the purpose of sending email notifications. Collecting more information than necessary can also increase the likelihood of data breaches, identity theft, fraud, or misuse of the data by unauthorized or malicious parties.
NEW QUESTION # 213
Under the General Data Protection Regulation (GDPR), which situation would be LEAST likely to require a Data Protection Impact Assessment (DPIA)?
Answer: D
Explanation:
A Data Protection Impact Assessment (DPIA) is a process to help identify and minimize the data protection risks of a project. Under the GDPR, a DPIA is required when the processing is likely to result in a high risk to the rights and freedoms of individuals, especially when using new technologies. The GDPR provides some examples of high-risk processing activities, such as systematic and extensive evaluation of personal aspects, large-scale processing of special categories of data, or systematic monitoring of public areas. The other options are more likely to require a DPIA than the online magazine using a mailing list to send a generic daily digest to marketing emails, as they involve more sensitive or intrusive types of processing. Reference:
[Data protection impact assessments | ICO]
[Art. 35 GDPR - Data protection impact assessment - GDPR.eu]
NEW QUESTION # 214
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