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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 |
| Assessing Data and Privacy Risks | 17–22% | - Risk identification, analysis and mitigation - Privacy impact assessments (PIA/DPIA) - Compliance gap analysis - Data inventory and mapping |
| Protecting Personal Data | 12–18% | - Privacy by design and default - Cross-border data transfers - Data lifecycle management - Technical and organizational safeguards |
| Responding to Requests and Incidents | 14–18% | - Breach detection, notification and remediation - Privacy incident response plan - Regulatory interaction and reporting - Data subject rights management |
| Sustaining Program Performance | 10–15% | - Change management - Continuous improvement - Monitoring, auditing and reporting - Performance metrics and KPIs |
| Establishing Program Governance | 17–22% | - Accountability and oversight mechanisms - Policies, procedures and standards - Training and awareness programs - Stakeholder engagement and communication |
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NEW QUESTION # 245
SCENARIO
Please use the following to answer the next QUESTION:
As they company's new chief executive officer, Thomas Goddard wants to be known as a leader in data protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically questionable practices, including unauthorized sales of personal data to marketers.
Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company's claims that
"appropriate" data protection safeguards were in place. The scandal affected the company's business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard's mentor, was forced to step down.
Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company's board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures.
He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. "We want Medialite to have absolutely the highest standards," he says. "In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company's finances. So, while I want the best solutions across the board, they also need to be cost effective." You are told to report back in a week's time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.
You are charged with making sure that privacy safeguards are in place for new products and initiatives. What is the best way to do this?
Answer: A
Explanation:
Privacy by Design principles ensure that privacy considerations are integrated from the very beginning and throughout the entire product or initiative development process. This proactive approach not only ensures that privacy safeguards are in place from the start but can also be more cost-effective in the long run as it helps prevent potential breaches or issues that might arise later, saving on potential fines, reputational damage, and corrective actions.
NEW QUESTION # 246
SCENARIO
Please use the following to answer the next QUESTION:
Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can be used in the home to manage family calendars, do online shopping, and schedule doctor appointments.
After having had a successful launch in the United States, the Handy Helper is about to be made available for purchase worldwide.
The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the whole family, including children, but does not provide any further detail or privacy notice. In order to use the application, a family creates a single account, and the primary user has access to all information about the other users. Upon start up, the primary user must check a box consenting to receive marketing emails from Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.
Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European distributor of Handy Helper when he fielded many Questions about the product from the distributor. Sanjay needed to look more closely at the product in order to be able to answer the Questions as he was not involved in the product development process.
In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the product. This data is all stored in the cloud and is encrypted both during transmission and at rest.
Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent Omnimedia employees have access to user data under a program called Eureka. Omnipresent Omnimedia is hoping that at some point in the future, the data will reveal insights that could be used to create a fully automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is considered a long-term goal.
What administrative safeguards should be implemented to protect the collected data while in use by Manasa and her product management team?
Answer: B
Explanation:
Explanation
An administrative safeguard that should be implemented to protect the collected data while in use by Manasa and her product management team is a policy restricting data access on a "need to know" basis. This means that only authorized personnel who have a legitimate business purpose for accessing the data should be able to do so3 This would help to prevent unauthorized or unnecessary access, use, or disclosure of sensitive or personal data by internal or external parties. It would also reduce the risk of data breaches, theft, or loss that could compromise the confidentiality, integrity, and availability of the data4 References: 3: HIPAA Security Series #2 - Administrative Safeguards - HHS.gov; 4: Administrative Safeguards of the Security Rule: What Are They?
NEW QUESTION # 247
SCENARIO
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 notification, which of the following would be the greatest concern?
Answer: B
NEW QUESTION # 248
SCENARIO
Please use the following to answer the next QUESTION:
Richard McAdams recently graduated law school and decided to return to the small town of Lexington, Virginia to help run his aging grandfather's law practice. The elder McAdams desired a limited, lighter role in the practice, with the hope that his grandson would eventually take over when he fully retires. In addition to hiring Richard, Mr. McAdams employs two paralegals, an administrative assistant, and a part-time IT specialist who handles all of their basic networking needs. He plans to hire more employees once Richard gets settled and assesses the office's strategies for growth.
Immediately upon arrival, Richard was amazed at the amount of work that needed to done in order to modernize the office, mostly in regard to the handling of clients' personal dat a. His first goal is to digitize all the records kept in file cabinets, as many of the documents contain personally identifiable financial and medical data. Also, Richard has noticed the massive amount of copying by the administrative assistant throughout the day, a practice that not only adds daily to the number of files in the file cabinets, but may create security issues unless a formal policy is firmly in place Richard is also concerned with the overuse of the communal copier/ printer located in plain view of clients who frequent the building. Yet another area of concern is the use of the same fax machine by all of the employees. Richard hopes to reduce its use dramatically in order to ensure that personal data receives the utmost security and protection, and eventually move toward a strict Internet faxing policy by the year's end.
Richard expressed his concerns to his grandfather, who agreed, that updating data storage, data security, and an overall approach to increasing the protection of personal data in all facets is necessary Mr. McAdams granted him the freedom and authority to do so. Now Richard is not only beginning a career as an attorney, but also functioning as the privacy officer of the small firm. Richard plans to meet with the IT employee the following day, to get insight into how the office computer system is currently set-up and managed.
Richard needs to closely monitor the vendor in charge of creating the firm's database mainly because of what?
Answer: D
Explanation:
The main reason why Richard needs to closely monitor the vendor in charge of creating the firm's database is that the vendor will be in direct contact with all of the law firm's personal data. This means that the vendor will have access to sensitive and confidential information about the law firm's clients, such as their financial and medical data, which could expose them to identity theft, fraud, or other harms if mishandled or breached. Therefore, Richard needs to ensure that the vendor follows the best practices of data protection and security, such as:
Signing a data processing agreement that specifies the scope, purpose, duration, and terms of the data processing activities, as well as the rights and obligations of both parties.
Implementing appropriate technical and organizational measures to protect the data from unauthorized or unlawful access, use, disclosure, alteration, or destruction, such as encryption, access control, backup and recovery, logging and monitoring, etc.
Complying with the relevant laws and regulations that govern the collection, use, transfer, and retention of personal data, such as the GDPR or other local privacy laws.
Reporting any data breaches or incidents to the law firm and the relevant authorities as soon as possible and taking corrective actions to mitigate the impact and prevent recurrence.
Deleting or returning the data to the law firm after the completion of the project or upon request.
NEW QUESTION # 249
What is a key feature of the privacy metric template adapted from the National Institute of Standards and Technology (NIST)?
Answer: B
Explanation:
A key feature of the privacy metric template adapted from the National Institute of Standards and Technology (NIST) is that it can be tailored to an organization's particular needs. The privacy metric template is a tool that helps organizations measure their privacy performance and outcomes based on their own goals and objectives7 The template consists of four components: privacy objective, privacy outcome category, privacy outcome statement, and privacy metric statement. The template allows organizations to customize each component according to their specific context, scope, scale, and level of detail8 The template also provides examples and guidance on how to use it effectively and consistently9 The other options are not key features of the privacy metric template adapted from NIST. The template does not provide suggestions on how to collect and measure data, but rather focuses on defining what data to collect and measure based on the desired privacy outcomes. The template is not updated annually to reflect changes in government policy, but rather reflects a general framework that can be applied across different sectors and jurisdictions. The template is not focused on organizations that do business internationally, but rather can be used by any organization regardless of its geographic scope or location. Reference: 7: Privacy Framework | NIST; 8: NIST Privacy Framework: A Tool for Improving Privacy through Enterprise Risk Management Version 1.0; 9: NIST Privacy Framework: A Tool for Improving Privacy through Enterprise Risk Management Version 1.0
NEW QUESTION # 250
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