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| Section | Weight | Objectives |
|---|---|---|
| Operational Life Cycle of a Privacy Program | 50% | - Monitoring, auditing, and continuous improvement - Implementing privacy controls and procedures - Managing data inventory and data flows - Assessing privacy risks and impacts |
| Privacy Program Governance | 50% | - Metrics, reporting, and accountability - Privacy program structure and governance models - Stakeholder engagement and communication - Policy development and implementation |
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NEW QUESTION # 262
An organization's internal audit team should do all of the following EXCEPT?
Answer: C
NEW QUESTION # 263
When developing a privacy program and selecting a program sponsor or "champion" the least important consideration should be that they?
Answer: C
NEW QUESTION # 264
SCENARIO
Please use the following to answer the next QUESTION:
Paul Daniels, with years of experience as a CEO, is worried about his son Carlton's successful venture, Gadgo.
A technological innovator in the communication industry that quickly became profitable, Gadgo has moved beyond its startup phase. While it has retained its vibrant energy, Paul fears that under Carlton's direction, the company may not be taking its risks or obligations as seriously as it needs to. Paul has hired you, a Privacy Consultant, to assess the company and report to both father and son. "Carlton won't listen to me," Paul says, "but he may pay attention to an expert." Gadgo's workplace is a clubhouse for innovation, with games, toys, snacks. espresso machines, giant fish tanks and even an iguana who regards you with little interest. Carlton, too, seems bored as he describes to you the company's procedures and technologies for data protection. It's a loose assemblage of controls, lacking consistency and with plenty of weaknesses. "This is a technology company," Carlton says. "We create. We innovate. I don't want unnecessary measures that will only slow people down and clutter their thoughts." The meeting lasts until early evening. Upon leaving, you walk through the office it looks as if a strong windstorm has recently blown through, with papers scattered across desks and tables and even the floor. A
"cleaning crew" of one teenager is emptying the trash bins. A few computers have been left on for the night, others are missing. Carlton takes note of your attention to this: "Most of my people take their laptops home with them, or use their own tablets or phones. I want them to use whatever helps them to think and be ready day or night for that great insight. It may only come once!" What phase in the Privacy Maturity Model (PMM) does Gadgo's privacy program best exhibit?
Answer: C
Explanation:
Explanation
This answer is the best way to describe the phase in the Privacy Maturity Model (PMM) that Gadgo's privacy program best exhibits, as it shows that the company has no formal or consistent approach to privacy protection and that its privacy practices are largely reactive, unplanned and uncoordinated. The ad hoc phase is the lowest level of maturity in the PMM, which is a framework that measures the effectiveness and maturity of an organization's privacy program based on five phases: ad hoc, repeatable, defined, managed and optimized. The ad hoc phase indicates that the organization has little or no awareness of its privacy obligations and risks, and that its privacy activities are dependent on individual efforts or initiatives, rather than on organizational policies or processes. References: IAPP CIPM Study Guide, page 891; ISO/IEC 27002:2013, section 18.1.1
NEW QUESTION # 265
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 data. 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.
Based on the scenario, what additional change will increase the effectiveness of the privacy compliance hotline?
Answer: C
Explanation:
Based on the scenario, an additional change that will increase the effectiveness of the privacy compliance hotline is a system for staff education. A privacy compliance hotline is a mechanism for employees, customers, or other stakeholders to report any concerns or violations of the company's privacy policy or applicable laws. However, a hotline alone is not sufficient to ensure a robust and compliant privacy program.
Employees also need to be educated and trained on the importance of privacy, the company's privacy policy and procedures, their roles and responsibilities, and the consequences of non-compliance. A system for staff education can help raise awareness, foster a culture of privacy, and prevent or mitigate potential risks. References: [Privacy Compliance Hotline], [Staff Education]
NEW QUESTION # 266
There are different forms of monitoring available for organizations to consider when aligning with their privacy program goals.
Which of the following forms of monitoring is best described as 'auditing'?
Answer: B
Explanation:
Evaluating operations, systems, and processes is best described as 'auditing', as it involves conducting a systematic and independent examination of the organization's privacy practices and controls to verify their effectiveness and compliance. The other options are more related to other forms of monitoring, such as complaint handling, reporting, and third-party oversight. Reference: CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 5: Monitor privacy program performance.
NEW QUESTION # 267
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