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| Section | Weight | Objectives |
|---|---|---|
| Establishing Program Governance | 17–22% | - Training and awareness programs - Policies, procedures and standards - Accountability and oversight mechanisms - Stakeholder engagement and communication |
| Responding to Requests and Incidents | 14–18% | - Privacy incident response plan - Data subject rights management - Breach detection, notification and remediation - Regulatory interaction and reporting |
| Sustaining Program Performance | 10–15% | - Monitoring, auditing and reporting - Change management - Continuous improvement - Performance metrics and KPIs |
| Developing a Privacy Program Framework | 15–20% | - Legal and regulatory requirements - Program scope and boundaries - Privacy vision, strategy and objectives - Program governance structure and roles |
| Protecting Personal Data | 12–18% | - Cross-border data transfers - Technical and organizational safeguards - Privacy by design and default - Data lifecycle management |
| Assessing Data and Privacy Risks | 17–22% | - Privacy impact assessments (PIA/DPIA) - Risk identification, analysis and mitigation - Data inventory and mapping - Compliance gap analysis |
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NEW QUESTION # 229
In addition to regulatory requirements and business practices, what important factors must a global privacy strategy consider?
Answer: B
Explanation:
In addition to regulatory requirements and business practices, an important factor that a global privacy strategy must consider is cultural norms. Different cultures may have different expectations and preferences regarding privacy, such as what constitutes personal information, how consent is obtained and expressed, how data is used and shared, and how privacy rights are enforced. A global privacy strategy should respect and accommodate these cultural differences and ensure that the organization's privacy practices are transparent, fair, and consistent across different regions. Reference: [IAPP CIPM Study Guide], page 81-82; [Cultural Differences in Privacy Expectations]
NEW QUESTION # 230
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 credit monitoring, which of the following would be the greatest concern?
Answer: B
Explanation:
Explanation
This answer is the greatest concern regarding the credit monitoring, as it may compromise the accuracy and effectiveness of the service, as well as expose the affected individuals to further privacy and security risks. The company did not collect enough identifiers to monitor one's credit means that the company only asked for the first name and the last-4 of their national identifier from the enrollees, which may not be sufficient or unique to identify and verify their identity and credit history. This may lead to errors, disputes or inaccuracies in the credit monitoring service, as well as potential identity theft, fraud or misuse of the data by unauthorized or malicious parties.
NEW QUESTION # 231
What does it mean to "rationalize" data protection requirements?
Answer: A
Explanation:
Explanation
To rationalize data protection requirements means to look for overlaps in laws and regulations from which a common solution can be developed. This can help simplify compliance efforts and reduce costs and complexity. References: IAPP CIPM Study Guide, page 16.
NEW QUESTION # 232
What United States federal law requires financial institutions to declare their personal data collection practices?
Answer: D
Explanation:
The United States federal law that requires financial institutions to declare their personal data collection practices is the Gramm-Leach-Bliley Act (GLBA) of 1999. The GLBA is also known as the Financial Services Modernization Act or the Financial Modernization Act10 The GLBA regulates how financial institutions collect, use, disclose, and protect the nonpublic personal information of their customers11 The GLBA requires financial institutions to provide a privacy notice to their customers that explains what kinds of information they collect, how they use and share that information, and how they safeguard that information12 The GLBA also gives customers the right to opt out of certain information sharing practices with third parties13 The other options are not US federal laws that require financial institutions to declare their personal data collection practices. The Kennedy-Hatch Disclosure Act of 1997 is a proposed but not enacted legislation that would have required health insurers to disclose their policies and practices regarding the use and disclosure of genetic information14 SUPCLA, or the federal Superprivacy Act of 2001, is a fictional law that does not exist in reality. The Financial Portability and Accountability Act of 2006 is also a fictional law that does not exist in reality, although it may be confused with the Health Insurance Portability and Accountability Act (HIPAA) of 1996, which regulates the privacy and security of health information15 Reference: 10: Gramm-Leach-Bliley Act | Federal Trade Commission; 11: Financial Privacy | Federal Trade Commission; 12: Financial Privacy | Federal Trade Commission; 13: Financial Privacy | Federal Trade Commission; 14: S. 422 (105th): Genetic Information Nondiscrimination in Health Insurance Act of 1997; 15: Health Information Privacy | HHS.gov
NEW QUESTION # 233
What should a privacy professional keep in mind when selecting which metrics to collect?
Answer: A
Explanation:
Explanation
A privacy professional should keep in mind that the number of metrics should be limited at first when selecting which metrics to collect. Metrics are quantitative measures that help evaluate the performance and effectiveness of a privacy program. However, collecting too many metrics can be overwhelming, confusing, and costly. Therefore, a privacy professional should start with a few key metrics that are relevant, meaningful, actionable, and aligned with the organization's privacy goals and priorities. These metrics can be refined and expanded over time as the privacy program matures and evolves. References: [Privacy Metrics], [Measuring Privacy Program Effectiveness]
NEW QUESTION # 234
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