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| Section | Objectives |
|---|---|
| Topic 1: Establishing Governance | - Define roles and responsibilities - Create privacy policies and procedures - Establish reporting mechanisms |
| Topic 2: Responding to Requests and Incidents | - Coordinate with regulators - Handle data subject requests - Manage data breaches and incidents |
| Topic 3: Assessing Data | - Manage vendor and third-party risks - Conduct data inventory and mapping - Perform privacy impact assessments |
| Topic 4: Protecting Personal Data | - Manage data subject rights - Implement privacy and security controls - Handle cross-border data transfers |
| Topic 5: Sustaining Program Performance | - Measure program effectiveness - Implement continuous improvement - Monitor and audit privacy program |
| Topic 6: Developing a Framework | - Define program scope and stakeholders - Identify applicable laws and frameworks - Establish privacy governance structure |
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NEW QUESTION # 77
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?
Which of the following would be most effectively used as a guide to a systems approach to implementing data protection?
Answer: C
Explanation:
Explanation/Reference: https://www.itgovernance.co.uk/blog/what-is-the-iso-27000-series-of-standards
NEW QUESTION # 78
Which is NOT an influence on the privacy environment external to an organization?
Answer: D
Explanation:
The privacy environment external to an organization refers to the factors that are outside the control of the organization, such as regulations, consumer demand, technological advances, and social norms. These factors can affect the organization's privacy practices and policies, and require the organization to adapt and comply. Management team priorities are an internal factor that influence the privacy environment within the organization, as they reflect the organization's vision, mission, values, and goals. Reference: CIPM Study Guide, page 14.
NEW QUESTION # 79
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 credit monitoring, which of the following would be the greatest concern?
Answer: A
Explanation:
Explanation
This answer is the greatest concern regarding the credit monitoring, as it may compromise the accuracy and effectiveness of the service, as well as expose the affected individuals to further privacy and security risks. The company did not collect enough identifiers to monitor one's credit means that the company only asked for the first name and the last-4 of their national identifier from the enrollees, which may not be sufficient or unique to identify and verify their identity and credit history. This may lead to errors, disputes or inaccuracies in the credit monitoring service, as well as potential identity theft, fraud or misuse of the data by unauthorized or malicious parties.
NEW QUESTION # 80
Which term describes a piece of personal data that alone may not identify an individual?
Answer: A
Explanation:
Explanation
A single attribute is a term that describes a piece of personal data that alone may not identify an individual, such as a first name or a zip code. However, when combined with other attributes, it may become identifiable. References: IAPP CIPM Study Guide, page 18.
NEW QUESTION # 81
If your organization has a recurring issue with colleagues not reporting personal data breaches, all of the following are advisable to do EXCEPT?
Answer: C
Explanation:
Distributing a phishing exercise to all employees is not advisable to do if your organization has a recurring issue with colleagues not reporting personal data breaches. A phishing exercise is a simulated attack that tests the awareness and response of employees to malicious emails that attempt to obtain sensitive information or compromise systems. While phishing exercises can be useful to train employees on how to recognize and avoid phishing attacks, they are not directly related to the issue of reporting personal data breaches. The other options are more appropriate to address the root cause of the issue, communicate the expectations and procedures for reporting breaches, and provide specific training to areas where breaches are happening1, 2. Reference: CIPM - International Association of Privacy Professionals, Free CIPM Study Guide - International Association of Privacy Professionals
NEW QUESTION # 82
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