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| Section | Weight | Objectives |
|---|---|---|
| Protecting Personal Data | 12–18% | - Cross-border data transfers - Privacy by design and default - Data lifecycle management - Technical and organizational safeguards |
| Sustaining Program Performance | 10–15% | - Continuous improvement - Monitoring, auditing and reporting - Performance metrics and KPIs - Change management |
| Establishing Program Governance | 17–22% | - Policies, procedures and standards - Training and awareness programs - Accountability and oversight mechanisms - Stakeholder engagement and communication |
| Developing a Privacy Program Framework | 15–20% | - Program scope and boundaries - Program governance structure and roles - Legal and regulatory requirements - Privacy vision, strategy and objectives |
| Responding to Requests and Incidents | 14–18% | - Breach detection, notification and remediation - Regulatory interaction and reporting - Data subject rights management - Privacy incident response plan |
| Assessing Data and Privacy Risks | 17–22% | - Compliance gap analysis - Privacy impact assessments (PIA/DPIA) - Risk identification, analysis and mitigation - Data inventory and mapping |
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NEW QUESTION # 272
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 key mistake set the company up to be vulnerable to a security breach?
Answer: D
NEW QUESTION # 273
Which of the following is the optimum first step to take when creating a Privacy Officer governance model?
Answer: B
Explanation:
The optimum first step to take when creating a Privacy Officer governance model is to involve senior leadership. Senior leadership plays a crucial role in establishing and supporting a privacy program within an organization. They can provide strategic direction, allocate resources, approve policies, endorse initiatives, communicate values, and demonstrate accountability. By involving senior leadership from the beginning, a Privacy Officer can ensure that the privacy program aligns with the organization's vision, mission, goals, and culture. Senior leadership can also help overcome potential barriers or resistance from other stakeholders by endorsing and promoting the privacy program.
Reference:
CIPM Body of Knowledge (2021), Domain I: Privacy Program Governance, Section A: Privacy Governance Models, Subsection 1: Privacy Officer Governance Model CIPM Study Guide (2021), Chapter 2: Privacy Governance Models, Section 2.1: Privacy Officer Governance Model CIPM Textbook (2019), Chapter 2: Privacy Governance Models, Section 2.1: Privacy Officer Governance Model CIPM Practice Exam (2021), Question 139
NEW QUESTION # 274
An organization's privacy officer was just notified by the benefits manager that she accidentally sent out the retirement enrollment report of all employees to a wrong vendor.
Which of the following actions should the privacy officer take first?
Answer: C
NEW QUESTION # 275
When conducting due diligence during an acquisition, what should a privacy professional avoid?
Answer: B
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 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]
NEW QUESTION # 276
An organization's privacy officer was just notified by the benefits manager that she accidentally sent out the retirement enrollment report of all employees to a wrong vendor.
Which of the following actions should the privacy officer take first?
Answer: C
Explanation:
The first action that the privacy officer should take after being notified by the benefits manager that she accidentally sent out the retirement enrollment report of all employees to a wrong vendor is to perform a risk of harm analysis. A risk of harm analysis is a process of assessing the potential adverse consequences for the individuals whose personal data has been compromised by a data breach or incident5 The purpose of this analysis is to determine whether the breach or incident poses a significant risk of harm to the affected individuals, such as identity theft, fraud, discrimination, physical harm, emotional distress, or reputational damage6 The risk of harm analysis should consider various factors, such as the type and amount of data involved, the sensitivity and context of the data, the likelihood and severity of harm, the characteristics of the recipients or unauthorized parties who accessed the data, and the mitigating measures taken or available to reduce the harm7 Based on this analysis, the privacy officer can then decide whether to notify the affected individuals, the relevant authorities, or other stakeholders about the breach or incident. Notification is usually required by law or best practice when there is a high risk of harm to the individuals as a result of the breach or incident8 Notification can also help to mitigate the harm by allowing the individuals to take protective actions or seek remedies. Therefore, performing a risk of harm analysis is a crucial first step for responding to a data breach or incident. References: 5: Can a risk of harm itself be a harm? | Analysis | Oxford Academic; 6: No Harm Done? Assessing Risk of Harm under the Federal Breach Notification Rule; 7: CCOHS: Hazard and Risk - Risk Assessment; 8: Breach Notification Requirements in Canada | PrivacySense.net
NEW QUESTION # 277
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