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| Section | Objectives |
|---|---|
| Topic 1: Developing a Framework | - Establish privacy governance structure - Identify applicable laws and frameworks - Define program scope and stakeholders |
| Topic 2: Sustaining Program Performance | - Measure program effectiveness - Implement continuous improvement - Monitor and audit privacy program |
| Topic 3: Assessing Data | - Conduct data inventory and mapping - Perform privacy impact assessments - Manage vendor and third-party risks |
| Topic 4: Protecting Personal Data | - Implement privacy and security controls - Handle cross-border data transfers - Manage data subject rights |
| Topic 5: Responding to Requests and Incidents | - Manage data breaches and incidents - Handle data subject requests - Coordinate with regulators |
| Topic 6: Establishing Governance | - Establish reporting mechanisms - Create privacy policies and procedures - Define roles and responsibilities |
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NEW QUESTION # 155
SCENARIO
Please use the following to answer the next QUESTION:
Martin Briseno is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseno decided to change the hotel's on-the-job mentoring model to a standardized training program for employees who were progressing from line positions into supervisory positions. He developed a curriculum comprising a series of lessons, scenarios, and assessments, which was delivered in-person to small groups. Interest in the training increased, leading Briseno to work with corporate HR specialists and software engineers to offer the program in an online format. The online program saved the cost of a trainer and allowed participants to work through the material at their own pace.
Upon hearing about the success of Briseno's program, Pacific Suites corporate Vice President Maryanne Silva-Hayes expanded the training and offered it company-wide. Employees who completed the program received certification as a Pacific Suites Hospitality Supervisor. By 2001, the program had grown to provide industry-wide training. Personnel at hotels across the country could sign up and pay to take the course online.
As the program became increasingly profitable, Pacific Suites developed an offshoot business, Pacific Hospitality Training (PHT). The sole focus of PHT was developing and marketing a variety of online courses and course progressions providing a number of professional certifications in the hospitality industry.
By setting up a user account with PHT, course participants could access an information library, sign up for courses, and take end-of-course certification tests. When a user opened a new account, all information was saved by default, including the user's name, date of birth, contact information, credit card information, employer, and job title. The registration page offered an opt-out choice that users could click to not have their credit card numbers saved. Once a user name and password were established, users could return to check their course status, review and reprint their certifications, and sign up and pay for new courses. Between 2002 and
2008, PHT issued more than 700,000 professional certifications.
PHT's profits declined in 2009 and 2010, the victim of industry downsizing and increased competition from e- learning providers. By 2011, Pacific Suites was out of the online certification business and PHT was dissolved. The training program's systems and records remained in Pacific Suites' digital archives, un- accessed and unused. Briseno and Silva-Hayes moved on to work for other companies, and there was no plan for handling the archived data after the program ended. After PHT was dissolved, Pacific Suites executives turned their attention to crucial day-to-day operations. They planned to deal with the PHT materials once resources allowed.
In 2012, the Pacific Suites computer network was hacked. Malware installed on the online reservation system exposed the credit card information of hundreds of hotel guests. While targeting the financial data on the reservation site, hackers also discovered the archived training course data and registration accounts of Pacific Hospitality Training's customers. The result of the hack was the exfiltration of the credit card numbers of recent hotel guests and the exfiltration of the PHT database with all its contents.
A Pacific Suites systems analyst discovered the information security breach in a routine scan of activity reports. Pacific Suites quickly notified credit card companies and recent hotel guests of the breach, attempting to prevent serious harm. Technical security engineers faced a challenge in dealing with the PHT data.
PHT course administrators and the IT engineers did not have a system for tracking, cataloguing, and storing information. Pacific Suites has procedures in place for data access and storage, but those procedures were not implemented when PHT was formed. When the PHT database was acquired by Pacific Suites, it had no owner or oversight. By the time technical security engineers determined what private information was compromised, at least 8,000 credit card holders were potential victims of fraudulent activity.
What key mistake set the company up to be vulnerable to a security breach?
Answer: D
NEW QUESTION # 156
What is a key feature of the privacy metric template adapted from the National Institute of Standards and Technology (NIST)?
Answer: B
Explanation:
Explanation
A key feature of the privacy metric template adapted from the National Institute of Standards and Technology (NIST) is that it can be tailored to an organization's particular needs. The privacy metric template is a tool that helps organizations measure their privacy performance and outcomes based on their own goals and objectives7 The template consists of four components: privacy objective, privacy outcome category, privacy outcome statement, and privacy metric statement. The template allows organizations to customize each component according to their specific context, scope, scale, and level of detail8 The template also provides examples and guidance on how to use it effectively and consistently9 The other options are not key features of the privacy metric template adapted from NIST. The template does not provide suggestions on how to collect and measure data, but rather focuses on defining what data to collect and measure based on the desired privacy outcomes. The template is not updated annually to reflect changes in government policy, but rather reflects a general framework that can be applied across different sectors and jurisdictions. The template is not focused on organizations that do business internationally, but rather can be used by any organization regardless of its geographic scope or location. References: 7: Privacy Framework | NIST; 8: NIST Privacy Framework: A Tool for Improving Privacy through Enterprise Risk Management Version 1.0; 9: NIST Privacy Framework: A Tool for Improving Privacy through Enterprise Risk Management Version 1.0
NEW QUESTION # 157
A new business crafting its privacy policy is struggling with how it will define the term "personal data." Which of the following should inform this decision?
Answer: C
Explanation:
Comprehensive and Detailed Explanation:
The definition of "personal data" must be based on applicable privacy laws (e.g., GDPR, CCPA, or LGPD), as different regulations define personal data differently.
NEW QUESTION # 158
When conducting due diligence during an acquisition, what should a privacy professional avoid?
Answer: C
Explanation:
When conducting due diligence during an acquisition, a privacy professional should avoid allowing legal in both companies to handle the privacy laws and compliance. This is because legal teams may not have the expertise or the resources to address all the privacy issues and risks that may arise from the acquisition. A privacy professional should be involved in the due diligence process to ensure that the privacy policies, practices, and obligations of both companies are aligned and compliant with the applicable laws and regulations. The other options are not things that a privacy professional should avoid, but rather things that they should do as part of the due diligence process. References: CIPM Body of Knowledge, Domain V:
Privacy Program Management, Section A: Privacy Program Administration, Subsection 3: Due Diligence.
NEW QUESTION # 159
A minimum requirement for carrying out a Data Protection Impact Assessment (DPIA) would include?
Answer: A
Explanation:
Explanation
Processing on a large scale of special categories of data is a minimum requirement for carrying out a Data Protection Impact Assessment (DPIA) under the General Data Protection Regulation (GDPR). A DPIA is a type of Privacy Impact Assessment (PIA) that is specifically required by the GDPR when a processing activity is likely to result in a high risk to the rights and freedoms of natural persons. According to Article 35(3)(b) of the GDPR, a DPIA is mandatory when the processing involves a large scale of special categories of data or personal data relating to criminal convictions and offences. Special categories of data are personal data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life or sexual orientation. These types of data are considered more sensitive and require more protection, as they may pose higher risks of discrimination, identity theft, fraud, or other harms to the data subjects.
References:
* CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section C:
Monitoring and Managing Program Performance Subsection 1: Privacy Impact Assessments
* CIPM Study Guide (2021), Chapter 9: Monitoring and Managing Program Performance Section 9.1:
Privacy Impact Assessments
* CIPM Textbook (2019), Chapter 9: Monitoring and Managing Program Performance Section 9.1:
Privacy Impact Assessments
* CIPM Practice Exam (2021), Question 147
* GDPR Article 35(3)(b) and Article 9
NEW QUESTION # 160
......
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