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IAPP CIPM Exam Syllabus Topics:

SectionWeightObjectives
Topic 1: Operational Life Cycle of a Privacy Program50%- Assessing privacy risks and impacts
- Managing data inventory and data flows
- Implementing privacy controls and procedures
- Monitoring, auditing, and continuous improvement
Topic 2: Privacy Program Governance50%- Stakeholder engagement and communication
- Privacy program structure and governance models
- Policy development and implementation
- Metrics, reporting, and accountability

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IAPP Certified Information Privacy Manager (CIPM) Sample Questions (Q67-Q72):

NEW QUESTION # 67
Under the General Data Protection Regulation (GDPR), what must be included in a written agreement between the controller and processor in relation to processing conducted on the controller's behalf?

Answer: A

Explanation:
Under the GDPR, a written agreement between the controller and processor must include an obligation on the processor to assist the controller in complying with the controller's obligations to notify the supervisory authority and the data subjects about personal data breaches. This is stated in Article 28(3)(f) of the GDPR1.
The other options are not required by the GDPR, although they may be included in the agreement as additional clauses. The obligation to report any personal data breach to the controller within 72 hours is imposed on the processor by Article 33(2) of the GDPR1, not by the agreement. The obligation to report any serious personal data breach to the supervisory authority is imposed on the controller by Article 33(1) of the GDPR1, not by the agreement. The termination of the agreement in case of a personal data breach is not a mandatory provision under the GDPR, but rather a contractual matter that may depend on the circumstances and severity of the breach. References: GDPR


NEW QUESTION # 68
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 analytic can be used to track the financial viability of the program as it develops?

Answer: D


NEW QUESTION # 69
What is the main function of the Asia-Pacific Economic Cooperation Privacy Framework?

Answer: C

Explanation:
Explanation/Reference: https://iapp.org/resources/article/apec-privacy-framework/


NEW QUESTION # 70
Formosa International operates in 20 different countries including the United States and France. What organizational approach would make complying with a number of different regulations easier?

Answer: A

Explanation:
Rationalizing requirements is an organizational approach that involves identifying and harmonizing the common elements of different privacy regulations and standards. This can make compliance easier and more efficient, as well as reduce the risk of conflicts or gaps in privacy protection. Rationalizing requirements can also help to create a consistent privacy policy and culture across different jurisdictions and business units. References: CIPM Study Guide, page 23.


NEW QUESTION # 71
SCENARIO
Please use the following to answer the next QUESTION:
Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new privacy officer. The company is based in California but thanks to some great publicity from a social media influencer last year, the company has received an influx of sales from the EU and has set up a regional office in Ireland to support this expansion. To become familiar with Ace Space's practices and assess what her privacy priorities will be, Penny has set up meetings with a number of colleagues to hear about the work that they have been doing and their compliance efforts.
Penny's colleague in Marketing is excited by the new sales and the company's plans, but is also concerned that Penny may curtail some of the growth opportunities he has planned. He tells her "I heard someone in the breakroom talking about some new privacy laws but I really don't think it affects us. We're just a small company. I mean we just sell accessories online, so what's the real risk?" He has also told her that he works with a number of small companies that help him get projects completed in a hurry. "We've got to meet our deadlines otherwise we lose money. I just sign the contracts and get Jim in finance to push through the payment. Reviewing the contracts takes time that we just don't have." In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken a number of precautions to protect its website from malicious activity, it has not taken the same level of care of its physical files or internal infrastructure. Penny's colleague in IT has told her that a former employee lost an encrypted USB key with financial data on it when he left. The company nearly lost access to their customer database last year after they fell victim to a phishing attack. Penny is told by her IT colleague that the IT team
"didn't know what to do or who should do what. We hadn't been trained on it but we're a small team though, so it worked out OK in the end." Penny is concerned that these issues will compromise Ace Space's privacy and data protection.
Penny is aware that the company has solid plans to grow its international sales and will be working closely with the CEO to give the organization a data "shake up". Her mission is to cultivate a strong privacy culture within the company.
Penny has a meeting with Ace Space's CEO today and has been asked to give her first impressions and an overview of her next steps.
To establish the current baseline of Ace Space's privacy maturity, Penny should consider all of the following factors EXCEPT?

Answer: D

Explanation:
The factor that Penny should not consider to establish the current baseline of Ace Space's privacy maturity is Ace Space's content sharing practices on social media. This is because this factor is not directly related to the privacy program elements that Penny should assess, such as leadership and organization, privacy risk management, engineering and information security, incident response, individual participation, transparency and redress, privacy training and awareness, and accountability1. The other factors are relevant to these elements and can help Penny measure the current state of Ace Space's privacy program against a recognized maturity model, such as the Privacy Capability Maturity Model (PCMM) developed by the Association of Corporate Counsel2. For example:
* Ace Space's documented procedures can help Penny evaluate the level of formalization and standardization of the privacy policies and practices across the organization, as well as the alignment with the applicable legal and regulatory requirements1, 2.
* Ace Space's employee training program can help Penny assess the level of awareness and competence of the staff on privacy issues and responsibilities, as well as the effectiveness and frequency of the training delivery and evaluation1, 2.
* Ace Space's vendor engagement protocols can help Penny determine the level of due diligence and oversight of the third parties that process personal data on behalf of Ace Space, as well as the contractual and technical safeguards that are in place to protect the data1, 2.


NEW QUESTION # 72
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