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| Section | Weight | Objectives |
|---|---|---|
| Privacy Program Governance | 50% | - Privacy program structure and governance models - Stakeholder engagement and communication - Metrics, reporting, and accountability - Policy development and implementation |
| Operational Life Cycle of a Privacy Program | 50% | - Implementing privacy controls and procedures - Monitoring, auditing, and continuous improvement - Managing data inventory and data flows - Assessing privacy risks and impacts |
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質問 # 109
What is the main function of the Asia-Pacific Economic Cooperation Privacy Framework?
正解:A
質問 # 110
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?
正解:C
質問 # 111
SCENARIO
Please use the following to answer the next QUESTION:
Edufox has hosted an annual convention of users of its famous e-learning software platform, and over time, it has become a grand event. It fills one of the large downtown conference hotels and overflows into the others, with several thousand attendees enjoying three days of presentations, panel discussions and networking. The convention is the centerpiece of the company's product rollout schedule and a great training opportunity for current users. The sales force also encourages prospective clients to attend to get a better sense of the ways in which the system can be customized to meet diverse needs and understand that when they buy into this system, they are joining a community that feels like family.
This year's conference is only three weeks away, and you have just heard news of a new initiative supporting it: a smartphone app for attendees. The app will support late registration, highlight the featured presentations and provide a mobile version of the conference program. It also links to a restaurant reservation system with the best cuisine in the areas featured. "It's going to be great," the developer, Deidre Hoffman, tells you, "if, that is, we actually get it working!" She laughs nervously but explains that because of the tight time frame she'd been given to build the app, she outsourced the job to a local firm. "It's just three young people," she says, "but they do great work." She describes some of the other apps they have built. When asked how they were selected for this job, Deidre shrugs. "They do good work, so I chose them." Deidre is a terrific employee with a strong track record. That's why she's been charged to deliver this rushed project. You're sure she has the best interests of the company at heart, and you don't doubt that she's under pressure to meet a deadline that cannot be pushed back. However, you have concerns about the app's handling of personal data and its security safeguards. Over lunch in the break room, you start to talk to her about it, but she quickly tries to reassure you, "I'm sure with your help we can fix any security issues if we have to, but I doubt there'll be any. These people build apps for a living, and they know what they're doing. You worry too much, but that's why you're so good at your job!" What safeguard can most efficiently ensure that privacy protection is a dimension of relationships with vendors?
正解:B
解説:
This answer is the best way to ensure that privacy protection is a dimension of relationships with vendors, as it can establish clear and binding terms and conditions for both parties regarding their roles and responsibilities for data processing activities. Including appropriate language about privacy protection in vendor contracts can help to define the scope, purpose, duration and type of data processing, as well as the rights and obligations of both parties. The contracts can also specify the technical and organizational measures that the vendor must implement to protect the data from unauthorized or unlawful access, use, disclosure, alteration or destruction, and to notify the organization of any security incidents or breaches. The contracts can also allow the organization to monitor, audit or inspect the vendor's performance and compliance with the contract terms and applicable laws and regulations. Reference: IAPP CIPM Study Guide, page 82; ISO/IEC 27002:2013, section 15.1.2
質問 # 112
Which of the following privacy frameworks are legally binding?
正解:C
解説:
Binding Corporate Rules (BCRs) are a set of legally binding rules that allow multinational corporations or groups of companies to transfer personal data across borders within their organization in compliance with the EU data protection law1 BCRs are approved by the competent data protection authorities in the EU and are enforceable by data subjects and the authorities2 BCRs are one of the mechanisms recognized by the EU General Data Protection Regulation (GDPR) to ensure an adequate level of protection for personal data transferred outside the European Economic Area (EEA)3
質問 # 113
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.
As Richard begins to research more about Data Lifecycle Management (DLM), he discovers that the law office can lower the risk of a data breach by doing what?
正解:D
解説:
As Richard begins to research more about Data Lifecycle Management (DLM), he discovers that the law office can lower the risk of a data breach by reducing the volume and the type of data that is stored in its system. This is because storing less data means having less data to protect and less data to lose in case of a breach. By reducing the volume and the type of data that is stored in its system, the law office can also comply with the data minimization principle under the GDPR and other data protection regulations, which requires that personal data should be adequate, relevant and limited to what is necessary for the purposes for which they are processed3 Therefore, this option is a way to lower the risk of a data breach.
The other options are not ways to lower the risk of a data breach by applying DLM principles. Prioritizing the data by order of importance may help to allocate resources and optimize performance, but it does not necessarily reduce the risk of a data breach. Minimizing the time it takes to retrieve the sensitive data may improve efficiency and responsiveness, but it does not necessarily reduce the risk of a data breach. Increasing the number of experienced staff to code and categorize the incoming data may enhance data quality and accuracy, but it does not necessarily reduce the risk of a data breach. Reference: 3: Article 5 GDPR | General Data Protection Regulation (GDPR); 4: Data Lifecycle Management: A Complete Guide | Splunk
質問 # 114
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