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| Section | Objectives |
|---|---|
| Topic 1: Responding to Requests and Incidents | - Coordinate with regulators - Handle data subject requests - Manage data breaches and incidents |
| Topic 2: Assessing Data | - Conduct data inventory and mapping - Manage vendor and third-party risks - Perform privacy impact assessments |
| Topic 3: Establishing Governance | - Define roles and responsibilities - Establish reporting mechanisms - Create privacy policies and procedures |
| Topic 4: Sustaining Program Performance | - Monitor and audit privacy program - Implement continuous improvement - Measure program effectiveness |
| Topic 5: Protecting Personal Data | - Handle cross-border data transfers - Implement privacy and security controls - Manage data subject rights |
| Topic 6: Developing a Framework | - Define program scope and stakeholders - Establish privacy governance structure - Identify applicable laws and frameworks |
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NEW QUESTION # 268
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.
How was Pacific Suites responsible for protecting the sensitive information of its offshoot, PHT?
Answer: B
NEW QUESTION # 269
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: D
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 # 270
What is one reason the European Union has enacted more comprehensive privacy laws than the United States?
Answer: C
Explanation:
One reason the European Union has enacted more comprehensive privacy laws than the United States is to allow the free movement of data between member countries. The EU considers data protection as a fundamental right that applies to all individuals within its territory, regardless of their nationality or residence. The EU has adopted a harmonized legal framework for data protection, such as the GDPR1 and the ePrivacy Directive5, that applies to all member states and ensures a consistent level of protection across the EU. The EU also requires that any transfers of personal data outside the EU are subject to adequate safeguards or exceptions that guarantee an equivalent level of protection. The EU's approach to data protection aims to facilitate the internal market and promote economic and social integration among member states by removing barriers and restrictions to the cross-border flow of data. The other options are not reasons why the EU has enacted more comprehensive privacy laws than the US. The EU does not necessarily have more adequate enforcement or funding for its privacy laws than the US, although it does have a network of independent supervisory authorities that monitor and enforce compliance with the EU data protection rules. The EU does not allow separate industries to set privacy standards, but rather imposes uniform and binding rules for all sectors and activities that involve personal data processing. Reference: GDPR; ePrivacy Directive
NEW QUESTION # 271
What is least likely to be achieved by implementing a Data Lifecycle Management (DLM) program?
Answer: C
Explanation:
Explanation
Crafting policies which ensure minimal data is collected is least likely to be achieved by implementing a Data Lifecycle Management (DLM) program, as it is more related to the data collection stage, not the data management stage. A DLM program focuses on how to handle the data after it has been collected, such as how to store, use, share, and dispose of it. The other options are more likely to be achieved by implementing a DLM program, as they help to optimize the data storage costs, comply with the data retention obligations, and protect the data confidentiality. References: CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 1: Manage data inventory.
NEW QUESTION # 272
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: D
Explanation:
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 # 273
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