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IAPP CIPM Exam Syllabus Topics:

SectionWeightObjectives
Responding to Requests and Incidents14–18%- Privacy incident response plan
- Regulatory interaction and reporting
- Breach detection, notification and remediation
- Data subject rights management
Establishing Program Governance17–22%- Policies, procedures and standards
- Accountability and oversight mechanisms
- Training and awareness programs
- Stakeholder engagement and communication
Assessing Data and Privacy Risks17–22%- Data inventory and mapping
- Compliance gap analysis
- Privacy impact assessments (PIA/DPIA)
- Risk identification, analysis and mitigation
Developing a Privacy Program Framework15–20%- Program scope and boundaries
- Program governance structure and roles
- Privacy vision, strategy and objectives
- Legal and regulatory requirements
Protecting Personal Data12–18%- Cross-border data transfers
- Privacy by design and default
- Technical and organizational safeguards
- Data lifecycle management
Sustaining Program Performance10–15%- Monitoring, auditing and reporting
- Performance metrics and KPIs
- Change management
- Continuous improvement

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IAPP Certified Information Privacy Manager (CIPM) Sample Questions (Q96-Q101):

NEW QUESTION # 96
SCENARIO
Please use the following to answer the next QUESTION:
For 15 years, Albert has worked at Treasure Box - a mail order company in the United States (U.S.) that used to sell decorative candles around the world, but has recently decided to limit its shipments to customers in the
48 contiguous states. Despite his years of experience, Albert is often overlooked for managerial positions. His frustration about not being promoted, coupled with his recent interest in issues of privacy protection, have motivated Albert to be an agent of positive change.
He will soon interview for a newly advertised position, and during the interview, Albert plans on making executives aware of lapses in the company's privacy program. He feels certain he will be rewarded with a promotion for preventing negative consequences resulting from the company's outdated policies and procedures.
For example, Albert has learned about the AICPA (American Institute of Certified Public Accountans)/CICA (Canadian Institute of Chartered Accountants) Privacy Maturity Model (PMM). Albert thinks the model is a useful way to measure Treasure Box's ability to protect personal data. Albert has noticed that Treasure Box fails to meet the requirements of the highest level of maturity of this model; at his interview, Albert will pledge to assist the company with meeting this level in order to provide customers with the most rigorous security available.
Albert does want to show a positive outlook during his interview. He intends to praise the company's commitment to the security of customer and employee personal data against external threats. However, Albert worries about the high turnover rate within the company, particularly in the area of direct phone marketing.
He sees many unfamiliar faces every day who are hired to do the marketing, and he often hears complaints in the lunch room regarding long hours and low pay, as well as what seems to be flagrant disregard for company procedures.
In addition, Treasure Box has had two recent security incidents. The company has responded to the incidents with internal audits and updates to security safeguards. However, profits still seem to be affected and anecdotal evidence indicates that many people still harbor mistrust. Albert wants to help the company recover.
He knows there is at least one incident the public in unaware of, although Albert does not know the details.
He believes the company's insistence on keeping the incident a secret could be a further detriment to its reputation. One further way that Albert wants to help Treasure Box regain its stature is by creating a toll-free number for customers, as well as a more efficient procedure for responding to customer concerns by postal mail.
In addition to his suggestions for improvement, Albert believes that his knowledge of the company's recent business maneuvers will also impress the interviewers. For example, Albert is aware of the company's intention to acquire a medical supply company in the coming weeks.
With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the job.
In consideration of the company's new initiatives, which of the following laws and regulations would be most appropriate for Albert to mention at the interview as a priority concern for the privacy team?

Answer: A

Explanation:
The most appropriate law for Albert to mention at the interview as a priority concern for the privacy team is the Health Insurance Portability and Accountability Act (HIPAA). HIPAA is a US federal law that establishes national standards for the protection of sensitive patient health information. HIPAA regulates the use, disclosure, and safeguarding of protected health information (PHI), which is any information that can identify a patient or relate to their health or health care services. HIPAA applies to covered entities, such as health plans, health care providers, and health care clearinghouses, and their business associates, such as vendors, contractors, or partners that access or handle PHI on their behalf. HIPAA requires covered entities and business associates to comply with the Privacy Rule, which sets forth the rights of individuals and the obligations of entities regarding PHI; the Security Rule, which specifies the administrative, technical, and physical safeguards to ensure the confidentiality, integrity, and availability of PHI; and the Breach Notification Rule, which requires the notification of individuals, HHS, and in some cases the media, in the event of a breach of unsecured PHI.
Since Treasure Box intends to acquire a medical supply company in the coming weeks, it is likely that it will become a business associate of some covered entities under HIPAA. Therefore, it will need to ensure that its privacy program is compliant with HIPAA requirements and that it has appropriate agreements and safeguards in place to protect PHI. Albert should mention this as a priority concern for the privacy team and demonstrate his awareness and knowledge of HIPAA.
The other options are not as relevant or important as HIPAA for Treasure Box's new initiatives. The Gramm- Leach-Bliley Act (GLBA) is a US federal law that requires financial institutions to explain how they share and protect their customers' non-public personal information. It also repealed the Glass-Steagall Act of 1933, which prohibited commercial banks from offering investment and insurance services. GLBA does not apply to Treasure Box since it is not a financial institution. The General Data Protection Regulation (GDPR) is an EU law that provides a comprehensive framework for the protection of personal data of individuals in the EU.
It imposes strict obligations and rights on data controllers and processors regarding the collection, use, disclosure, and security of personal data. GDPR does not apply to Treasure Box since it has recently decided to limit its shipments to customers in the 48 contiguous states of the US. The Telephone Consumer Protection Act (TCPA) is a US federal law that restricts telemarketing calls, text messages, faxes, and prerecorded messages. It requires prior express consent from consumers before making such communications and provides consumers with the right to opt out or revoke their consent. TCPA may apply to Treasure Box since it engages in direct phone marketing, but it is not a new initiative or a priority concern for the privacy team. References: HIPAA; GLBA; GDPR; [TCPA]


NEW QUESTION # 97
SCENARIO
Please use the following to answer the next QUESTION:
Ben works in the IT department of IgNight, Inc., a company that designs lighting solutions for its clients.
Although IgNight's customer base consists primarily of offices in the US, some individuals have been so impressed by the unique aesthetic and energy-saving design of the light fixtures that they have requested IgNight's installations in their homes across the globe.
One Sunday morning, while using his work laptop to purchase tickets for an upcoming music festival, Ben happens to notice some unusual user activity on company files. From a cursory review, all the data still appears to be where it is meant to be but he can't shake off the feeling that something is not right. He knows that it is a possibility that this could be a colleague performing unscheduled maintenance, but he recalls an email from his company's security team reminding employees to be on alert for attacks from a known group of malicious actors specifically targeting the industry.
Ben is a diligent employee and wants to make sure that he protects the company but he does not want to bother his hard-working colleagues on the weekend. He is going to discuss the matter with this manager first thing in the morning but wants to be prepared so he can demonstrate his knowledge in this area and plead his case for a promotion.
To determine the steps to follow, what would be the most appropriate internal guide for Ben to review?

Answer: A


NEW QUESTION # 98
SCENARIO
Please use the following to answer the next question
You were recently hired by InStyte Date Corp as a privacy manager to help InStyle Data Corp become compliant with a new data protection law The law mandates that businesses have reasonable and appropriate security measures in place to protect personal data. Violations of that mandate are heavily fined and the legislators have stated that they will aggressively pursue companies that don t comply with the new law You are paved with a security manager and tasked with reviewing InStyle Data Corp s current state and advising the business how it can meet the "reasonable and appropriate security" requirement InStyle Data Corp has grown rapidly and has not kept a data inventory or completed a data mapping InStyte Data Corp has also developed security-related policies ad hoc and many have never been implemented The various teams involved in the creation and testing of InStyle Data Corp s products experience significant turnover and do not have well defined roles There's little documentation addressing what personal data is processed by which product and for what purpose Work needs to begin on this project immediately so that InStyle Data Corp can become compliant by the time the law goes into effect. You and you partner discover that InStyle Data Corp regularly sends files containing sensitive personal data back to its customers through email sometimes using InStyle Data Corp employees personal email accounts. You also team that InStyle Data Corp s privacy and information security teams are not informed of new personal data flows, new products developed by InStyte Data Corp that process personal data, or updates to existing InStyle Data Corp products that may change what or how the personal data is processed until after the product or update has gone have.
Through a review of InStyle Date Corp's test and development environment logs, you discover InStyle Data Corp sometimes gives login credentials to any InStyle Data Corp employee or contractor who requests them.
The test environment only contains dummy data but the development environment contains personal data including Social Security Numbers, hearth

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