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| Section | Weight | Objectives |
|---|---|---|
| Responding to Requests and Incidents | 14–18% | - Data subject rights management - Regulatory interaction and reporting - Breach detection, notification and remediation - Privacy incident response plan |
| Developing a Privacy Program Framework | 15–20% | - Program scope and boundaries - Legal and regulatory requirements - Privacy vision, strategy and objectives - Program governance structure and roles |
| Sustaining Program Performance | 10–15% | - Continuous improvement - Performance metrics and KPIs - Monitoring, auditing and reporting - Change management |
| Establishing Program Governance | 17–22% | - Accountability and oversight mechanisms - Policies, procedures and standards - Stakeholder engagement and communication - Training and awareness programs |
| Protecting Personal Data | 12–18% | - Cross-border data transfers - Technical and organizational safeguards - Privacy by design and default - Data lifecycle management |
| Assessing Data and Privacy Risks | 17–22% | - Privacy impact assessments (PIA/DPIA) - Data inventory and mapping - Risk identification, analysis and mitigation - Compliance gap analysis |
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NEW QUESTION # 33
SCENARIO
Please use the following to answer the next QUESTION:
Amira is thrilled about the sudden expansion of NatGen. As the joint Chief Executive Officer (CEO) with her long-time business partner Sadie, Amira has watched the company grow into a major competitor in the green energy market. The current line of products includes wind turbines, solar energy panels, and equipment for geothermal systems. A talented team of developers means that NatGen's line of products will only continue to grow.
With the expansion, Amira and Sadie have received advice from new senior staff members brought on to help manage the company's growth. One recent suggestion has been to combine the legal and security functions of the company to ensure observance of privacy laws and the company's own privacy policy. This sounds overly complicated to Amira, who wants departments to be able to use, collect, store, and dispose of customer data in ways that will best suit their needs. She does not want administrative oversight and complex structuring to get in the way of people doing innovative work.
Sadie has a similar outlook. The new Chief Information Officer (CIO) has proposed what Sadie believes is an unnecessarily long timetable for designing a new privacy program. She has assured him that NatGen will use the best possible equipment for electronic storage of customer and employee dat a. She simply needs a list of equipment and an estimate of its cost. But the CIO insists that many issues are necessary to consider before the company gets to that stage.
Regardless, Sadie and Amira insist on giving employees space to do their jobs. Both CEOs want to entrust the monitoring of employee policy compliance to low-level managers. Amira and Sadie believe these managers can adjust the company privacy policy according to what works best for their particular departments. NatGen's CEOs know that flexible interpretations of the privacy policy in the name of promoting green energy would be highly unlikely to raise any concerns with their customer base, as long as the data is always used in course of normal business activities.
Perhaps what has been most perplexing to Sadie and Amira has been the CIO's recommendation to institute a privacy compliance hotline. Sadie and Amira have relented on this point, but they hope to compromise by allowing employees to take turns handling reports of privacy policy violations. The implementation will be easy because the employees need no special preparation. They will simply have to document any concerns they hear.
Sadie and Amira are aware that it will be challenging to stay true to their principles and guard against corporate culture strangling creativity and employee morale. They hope that all senior staff will see the benefit of trying a unique approach.
What Data Lifecycle Management (DLM) principle should the company follow if they end up allowing departments to interpret the privacy policy differently?
Answer: C
Explanation:
If the company ends up allowing departments to interpret the privacy policy differently, they should follow the Data Lifecycle Management (DLM) principle of adequately documenting reasons for inconsistencies. This principle requires that data should be accurate, complete, and consistent throughout its lifecycle and that any deviations or discrepancies should be justified and recorded1 This would help the company to maintain data quality and integrity, as well as to demonstrate accountability and compliance with data protection regulations2 The other options are not DLM principles that the company should follow if they allow departments to interpret the privacy policy differently. Proving the authenticity of the company's records is a principle related to data preservation and archiving, not data interpretation3 Arranging for official credentials for staff members is a principle related to data access and security, not data interpretation4 Creating categories to reflect degrees of data importance is a principle related to data classification and retention, not data interpretation5 Reference: 1: Data Lifecycle Management: A Complete Guide | Splunk; 2: Data Lifecycle Management | IBM; 3: Data Preservation | Digital Preservation Handbook; 4: Data Access Management Best Practices | Smartsheet; 5: Data Classification: What It Is And How To Do It | Varonis
NEW QUESTION # 34
Under the GDPR. when the applicable lawful basis for the processing of personal data is a legal obligation with which the controller must comply. which right can the data subject exercise?
Answer: C
Explanation:
Explanation
Under the GDPR, when the applicable lawful basis for the processing of personal data is a legal obligation with which the controller must comply, the data subject can exercise the right to restriction. This means that the data subject can request the controller to limit the processing of their personal data in certain circumstances, such as when they contest the accuracy or lawfulness of the processing. The other rights are not applicable in this case, as they are either dependent on consent (right to withdraw consent and right to data portability) or subject to exceptions (right to erasure). References: GDPR, Articles 6(1), 18, 21(1).
NEW QUESTION # 35
Under the General Data Protection Regulation (GDPR), when would a data subject have the right to require the erasure of his or her data without undue delay?
Answer: A
NEW QUESTION # 36
SCENARIO
Please use the following to answer the next QUESTION:
Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can be used in the home to manage family calendars, do online shopping, and schedule doctor appointments.
After having had a successful launch in the United States, the Handy Helper is about to be made available for purchase worldwide.
The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the whole family, including children, but does not provide any further detail or privacy notice. In order to use the application, a family creates a single account, and the primary user has access to all information about the other users. Upon start up, the primary user must check a box consenting to receive marketing emails from Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.
Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European distributor of Handy Helper when he fielded many Questions about the product from the distributor. Sanjay needed to look more closely at the product in order to be able to answer the Questions as he was not involved in the product development process.
In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the product. This data is all stored in the cloud and is encrypted both during transmission and at rest.
Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent Omnimedia employees have access to user data under a program called Eureka. Omnipresent Omnimedia is hoping that at some point in the future, the data will reveal insights that could be used to create a fully automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is considered a long-term goal.
What step in the system development process did Manasa skip?
Answer: A
Explanation:
Manasa skipped the step of working with Sanjay to review any necessary privacy requirements to be built into the product. This step is part of the system analysis phase, which is less theoretical and focuses more on practical application1 By working with Sanjay, Manasa could have identified the legal and ethical obligations that Omnipresent Omnimedia has to protect the privacy of its users, especially in different jurisdictions. She could have also incorporated privacy by design principles, such as data minimization, purpose limitation, and user consent, into the product development process2 This would have helped to avoid potential privacy risks and violations that could harm the reputation and trust of the company and its customers. References: 1: 7 Phases of the System Development Life Cycle (With Tips); 2: [Privacy by Design: The 7 Foundational Principles]
NEW QUESTION # 37
Which is the best way to view an organization's privacy framework?
Answer: B
Explanation:
The best way to view an organization's privacy framework is as a living structure that aligns to changes in the organization, such as business goals, stakeholder expectations, legal requirements, and technological developments. A privacy framework should be flexible and adaptable to support the organization's privacy strategy and vision. It should also be compatible with other frameworks, such as the cybersecurity framework, that the organization may use. Reference: IAPP CIPM Study Guide, page 16.
NEW QUESTION # 38
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