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| Section | Weight | Objectives |
|---|---|---|
| Operational Life Cycle of a Privacy Program | 50% | - Assessing privacy risks and impacts - Managing data inventory and data flows - Monitoring, auditing, and continuous improvement - Implementing privacy controls and procedures |
| Privacy Program Governance | 50% | - Privacy program structure and governance models - Stakeholder engagement and communication - Metrics, reporting, and accountability - Policy development and implementation |
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問題 #143
When conducting due diligence during an acquisition, what should a privacy professional avoid?
答案：C
解題說明：
Explanation
When conducting due diligence during an acquisition, a privacy professional should avoid allowing legal in both companies to handle the privacy laws and compliance. This is because legal teams may not have the expertise or the resources to address all the privacy issues and risks that may arise from the acquisition. A privacy professional should be involved in the due diligence process to ensure that the privacy policies, practices, and obligations of both companies are aligned and compliant with the applicable laws and regulations. The other options are not things that a privacy professional should avoid, but rather things that they should do as part of the due diligence process. References: CIPM Body of Knowledge, Domain V:
Privacy Program Management, Section A: Privacy Program Administration, Subsection 3: Due Diligence.
問題 #144
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.
What must Pacific Suite's primary focus be as it manages this security breach?
答案：B
問題 #145
SCENARIO
Please use the following to answer the next QUESTION:
Perhaps Jack Kelly should have stayed in the U.S. He enjoys a formidable reputation inside the company, Special Handling Shipping, for his work in reforming certain "rogue" offices. Last year, news broke that a police sting operation had revealed a drug ring operating in the Providence, Rhode Island office in the United States. Video from the office's video surveillance cameras leaked to news operations showed a drug exchange between Special Handling staff and undercover officers.
In the wake of this incident, Kelly had been sent to Providence to change the "hands off" culture that upper management believed had let the criminal elements conduct their illicit transactions. After a few weeks under Kelly's direction, the office became a model of efficiency and customer service. Kelly monitored his workers' activities using the same cameras that had recorded the illegal conduct of their former co-workers.
Now Kelly has been charged with turning around the office in Cork, Ireland, another trouble spot. The company has received numerous reports of the staff leaving the office unattended. When Kelly arrived, he found that even when present, the staff often spent their days socializing or conducting personal business on their mobile phones. Again, he observed their behaviors using surveillance cameras. He issued written reprimands to six staff members based on the first day of video alone.
Much to Kelly's surprise and chagrin, he and the company are now under investigation by the Data Protection Commissioner of Ireland for allegedly violating the privacy rights of employees. Kelly was told that the company's license for the cameras listed facility security as their main use, but he does not know why this matters. He has pointed out to his superiors that the company's training programs on privacy protection and data collection mention nothing about surveillance video.
You are a privacy protection consultant, hired by the company to assess this incident, report on the legal and compliance issues, and recommend next steps.
What should you advise this company regarding the status of security cameras at their offices in the United States?
答案：D
解題說明：
This answer is the best way to advise this company regarding the status of security cameras at their offices in the United States, as it can help to protect the privacy and security of the employees and visitors who are recorded by the cameras, as well as to comply with any applicable laws and regulations that may limit or regulate the use of surveillance video. Restricting access to surveillance video means that only authorized personnel who have a legitimate business need can view, copy, share or disclose the video, and that they must follow proper procedures and safeguards to prevent unauthorized or unlawful access, use or disclosure. Destroying the recordings after a designated period of time means that the video is not kept longer than necessary for the purpose for which it was collected, and that it is disposed of securely and irreversibly. The designated period of time should be based on the legal, operational and risk factors that may affect the retention of the video, such as potential litigation, investigations, audits or claims. Reference: IAPP CIPM Study Guide, page 831; ISO/IEC 27002:2013, section 8.3.2
問題 #146
In a sample metric template, what does "target" mean?
答案：B
解題說明：
Explanation
In a sample metric template, the target is the threshold for a satisfactory rating. It is the desired or expected value for the metric that indicates a successful performance or outcome. For example, if the metric is the percentage of employees who completed privacy training, the target could be 90% or higher. References: IAPP CIPM Study Guide, page 22.
問題 #147
When conducting due diligence during an acquisition, what should a privacy professional avoid?
答案：C
解題說明：
When conducting due diligence during an acquisition, a privacy professional should avoid allowing legal in both companies to handle the privacy laws and compliance. This is because privacy is not only a legal issue, but also a business, technical, and operational issue that requires cross-functional collaboration and expertise.
A privacy professional should be involved in the due diligence process to assess the privacy risks and opportunities of the acquisition, such as the type and scope of data processing, the data protection policies and practices, the data transfer mechanisms and agreements, the data breach history and response plans, and the impacts on the data processing operations post-acquisition. A privacy professional should also benchmark the two companies' privacy policies against one another to identify any gaps or inconsistencies that need to be addressed before or after the acquisition, . References: [CIPM - International Association of Privacy Professionals], [Free CIPM Study Guide - International Association of Privacy Professionals]
問題 #148
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