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| Section | Weight | Objectives |
|---|---|---|
| Developing a Privacy Program Framework | 15–20% | - Program scope and boundaries - Legal and regulatory requirements - Program governance structure and roles - Privacy vision, strategy and objectives |
| Establishing Program Governance | 17–22% | - Accountability and oversight mechanisms - Training and awareness programs - Stakeholder engagement and communication - Policies, procedures and standards |
| Responding to Requests and Incidents | 14–18% | - Regulatory interaction and reporting - Breach detection, notification and remediation - Privacy incident response plan - Data subject rights management |
| Sustaining Program Performance | 10–15% | - Continuous improvement - Performance metrics and KPIs - Monitoring, auditing and reporting - Change management |
| Protecting Personal Data | 12–18% | - Technical and organizational safeguards - Privacy by design and default - Cross-border data transfers - Data lifecycle management |
| Assessing Data and Privacy Risks | 17–22% | - Risk identification, analysis and mitigation - Compliance gap analysis - Privacy impact assessments (PIA/DPIA) - Data inventory and mapping |
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NEW QUESTION # 133
Which is NOT an influence on the privacy environment external to an organization?
Answer: C
NEW QUESTION # 134
An organization's business continuity plan or disaster recovery plan does NOT typically include what?
Answer: A
Explanation:
An organization's business continuity plan or disaster recovery plan does not typically include a retention schedule for storage and destruction of information. A retention schedule is a document that specifies how long different types of information should be kept by an organization before they are disposed of or destroyed. A retention schedule is usually based on legal, regulatory, operational, historical, or archival requirements. A retention schedule is part of an organization's information governance or records management policy, not its business continuity or disaster recovery plan.
A business continuity plan (BCP) is a document that outlines how an organization will continue its critical functions and operations in the event of a disruption or disaster. A BCP usually includes:
Contact information and service level agreements (SLAs) for key personnel, stakeholders, providers, backup site operators, etc.
Business impact analysis (BIA) that identifies the potential impacts of disruption on all aspects of the business, such as financial, legal, reputational, etc.
Risk assessment that identifies and evaluates the likelihood and severity of various threats and vulnerabilities that could cause disruption or disaster.
Identification of critical functions that are essential for the survival and recovery of the business.
Communications plan that specifies how to communicate with internal and external parties during and after a disruption or disaster.
Testing plan that specifies how to test and update the BCP regularly to ensure its effectiveness and validity.
A disaster recovery plan (DRP) is a document that outlines how an organization will restore its IT systems, data, applications, and infrastructure in the event of a disruption or disaster. A DRP usually includes:
Recovery time objectives (RTOs) that specify how quickly each IT system or service needs to be restored after a disruption or disaster.
Recovery point objectives (RPOs) that specify how much data loss is acceptable for each IT system or service after a disruption or disaster.
Emergency response guidelines that specify how to respond to and contain a disruption or disaster, such as activating the DRP, declaring a disaster, notifying the stakeholders, etc.
Statement of organizational responsibilities that specifies who is responsible for what tasks and roles during and after a disruption or disaster, such as initiating the DRP, executing the recovery procedures, restoring the IT systems or services, etc.
Recovery procedures that specify how to recover each IT system or service from backup sources, such as backup tapes, disks, cloud services, etc.
Testing plan that specifies how to test and update the DRP regularly to ensure its effectiveness and validity. Reference: [Business Continuity Plan (BCP) Definition]; [Disaster Recovery Plan (DRP) Definition]
NEW QUESTION # 135
Which of the following information must be provided by the data controller when complying with GDPR "right to be informed" requirements?
Answer: D
NEW QUESTION # 136
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 dat a. 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.
Based on Albert's observations, executive leadership should most likely pay closer attention to what?
Answer: D
NEW QUESTION # 137
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.
What information will be LEAST crucial from a privacy perspective in Penny's review of vendor contracts?
Answer: B
Explanation:
Explanation
The information that will be least crucial from a privacy perspective in Penny's review of vendor contracts is the pricing for data security protections . This is because the pricing for data security protections is a business decision that does not directly affect the privacy rights and obligations of Ace Space and its customers. The pricing for data security protections may be relevant for budgeting and negotiating purposes, but it does not determine the level or adequacy of data security measures that the vendor must provide to protect personal data.
The other options are more crucial from a privacy perspective in Penny's review of vendor contracts. Audit rights (A) are important to ensure that Ace Space can monitor and verify the vendor's compliance with the contract terms and the applicable privacy laws and regulations. Audit rights allow Ace Space to access the vendor's records, systems, policies and procedures related to personal data processing and to conduct inspections or assessments as needed. Liability for a data breach (B) is important to allocate the responsibility and consequences of a data breach involving personal data that the vendor processes on behalf of Ace Space.
Liability for a data breach may include indemnification, compensation, notification, remediation and termination clauses that protect Ace Space's interests and obligations in the event of a data breach. The data a vendor will have access to (D) is important to define the scope, purpose, duration and conditions of the personal data processing that the vendor will perform for Ace Space. The data a vendor will have access to may include the categories, types, sources, recipients and retention periods of personal data that the vendor will collect, store, use or share on behalf of Ace Space.
References:
* CIPM Body of Knowledge Domain II: Privacy Program Operational Life Cycle - Task 3: Implement
* privacy program components - Subtask 3: Establish third-party processor management program
* CIPM Study Guide - Chapter 4: Privacy Program Operational Life Cycle - Section 4.3: Third-Party Processor Management
NEW QUESTION # 138
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