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| Section | Weight | Objectives |
|---|---|---|
| Protecting Personal Data | 12–18% | - Cross-border data transfers - Privacy by design and default - Data lifecycle management - Technical and organizational safeguards |
| Assessing Data and Privacy Risks | 17–22% | - Privacy impact assessments (PIA/DPIA) - Data inventory and mapping - Compliance gap analysis - Risk identification, analysis and mitigation |
| Establishing Program Governance | 17–22% | - Training and awareness programs - Policies, procedures and standards - Stakeholder engagement and communication - Accountability and oversight mechanisms |
| Responding to Requests and Incidents | 14–18% | - Breach detection, notification and remediation - Data subject rights management - Privacy incident response plan - Regulatory interaction and reporting |
| Sustaining Program Performance | 10–15% | - Continuous improvement - Change management - Monitoring, auditing and reporting - Performance metrics and KPIs |
| Developing a Privacy Program Framework | 15–20% | - Legal and regulatory requirements - Privacy vision, strategy and objectives - Program scope and boundaries - Program governance structure and roles |
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NEW QUESTION # 133
What does it mean to "rationalize" data protection requirements?
Answer: A
NEW QUESTION # 134
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.
What is the most realistic step the organization can take to help diminish liability in the event of another incident?
Answer: B
NEW QUESTION # 135
What is one reason the European Union has enacted more comprehensive privacy laws than the United States?
Answer: D
Explanation:
One reason the European Union has enacted more comprehensive privacy laws than the United States is to allow the free movement of data between member countries. The EU considers data protection as a fundamental right that applies to all individuals within its territory, regardless of their nationality or residence. The EU has adopted a harmonized legal framework for data protection, such as the GDPR1 and the ePrivacy Directive5, that applies to all member states and ensures a consistent level of protection across the EU. The EU also requires that any transfers of personal data outside the EU are subject to adequate safeguards or exceptions that guarantee an equivalent level of protection. The EU's approach to data protection aims to facilitate the internal market and promote economic and social integration among member states by removing barriers and restrictions to the cross-border flow of data. The other options are not reasons why the EU has enacted more comprehensive privacy laws than the US. The EU does not necessarily have more adequate enforcement or funding for its privacy laws than the US, although it does have a network of independent supervisory authorities that monitor and enforce compliance with the EU data protection rules. The EU does not allow separate industries to set privacy standards, but rather imposes uniform and binding rules for all sectors and activities that involve personal data processing. References: GDPR; ePrivacy Directive
NEW QUESTION # 136
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: C
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. Reference: IAPP CIPM Study Guide, page 90; ISO/IEC 27002:2013, section 7.2.2
NEW QUESTION # 137
A Human Resources director at a company reported that a laptop containing employee payroll data was lost on the train. Which action should the company take IMMEDIATELY?
Answer: B
Explanation:
The company should perform a multi-factor risk analysis immediately after discovering the loss of the laptop containing employee payroll data. A multi-factor risk analysis is a process of assessing the potential impact and likelihood of a data breach, taking into account various factors such as the nature, scope, context, and purpose of the processing, the type and severity of the harm that may result from the breach, the number and categories of data subjects and personal data affected, the measures taken to mitigate the risk, and any relevant legal obligations or codes of conduct. A multi-factor risk analysis can help the company determine whether the breach poses a high risk to the rights and freedoms of the data subjects, and whether it needs to notify them and/or the relevant supervisory authority without undue delay, as required by Article 33 and 34 of the GDPR1. A multi-factor risk analysis can also help the company identify the root cause of the breach, evaluate the effectiveness of its existing security measures, and implement appropriate corrective actions to prevent or minimize similar incidents in the future.
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 Management2 CIPM Study Guide (2021), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management3 CIPM Textbook (2019), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management4 CIPM Practice Exam (2021), Question 1285 GDPR Article 33 and 341
NEW QUESTION # 138
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