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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Responding to Requests and Incidents | 14–18% | - Breach detection, notification and remediation - Regulatory interaction and reporting - Privacy incident response plan - Data subject rights management |
| Topic 2: Assessing Data and Privacy Risks | 17–22% | - Compliance gap analysis - Risk identification, analysis and mitigation - Data inventory and mapping - Privacy impact assessments (PIA/DPIA) |
| Topic 3: Sustaining Program Performance | 10–15% | - Monitoring, auditing and reporting - Performance metrics and KPIs - Continuous improvement - Change management |
| Topic 4: Protecting Personal Data | 12–18% | - Cross-border data transfers - Technical and organizational safeguards - Data lifecycle management - Privacy by design and default |
| Topic 5: Establishing Program Governance | 17–22% | - Policies, procedures and standards - Training and awareness programs - Accountability and oversight mechanisms - Stakeholder engagement and communication |
| Topic 6: Developing a Privacy Program Framework | 15–20% | - Program scope and boundaries - Privacy vision, strategy and objectives - Program governance structure and roles - Legal and regulatory requirements |
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NEW QUESTION # 183
SCENARIO
Please use the following to answer the next QUESTION:
Your organization, the Chicago (U.S.)-based Society for Urban Greenspace, has used the same vendor to operate all aspects of an online store for several years. As a small nonprofit, the Society cannot afford the higher-priced options, but you have been relatively satisfied with this budget vendor, Shopping Cart Saver (SCS). Yes, there have been some issues. Twice, people who purchased items from the store have had their credit card information used fraudulently subsequent to transactions on your site, but in neither case did the investigation reveal with certainty that the Society's store had been hacked. The thefts could have been employee-related.
Just as disconcerting was an incident where the organization discovered that SCS had sold information it had collected from customers to third parties. However, as Jason Roland, your SCS account representative, points out, it took only a phone call from you to clarify expectations and the "misunderstanding" has not occurred again.
As an information-technology program manager with the Society, the role of the privacy professional is only one of many you play. In all matters, however, you must consider the financial bottom line. While these problems with privacy protection have been significant, the additional revenues of sales of items such as shirts and coffee cups from the store have been significant. The Society's operating budget is slim, and all sources of revenue are essential.
Now a new challenge has arisen. Jason called to say that starting in two weeks, the customer data from the store would now be stored on a data cloud. "The good news," he says, "is that we have found a low-cost provider in Finland, where the data would also be held. So, while there may be a small charge to pass through to you, it won't be exorbitant, especially considering the advantages of a cloud." Lately, you have been hearing about cloud computing and you know it's fast becoming the new paradigm for various applications. However, you have heard mixed reviews about the potential impacts on privacy protection. You begin to research and discover that a number of the leading cloud service providers have signed a letter of intent to work together on shared conventions and technologies for privacy protection. You make a note to find out if Jason's Finnish provider is signing on.
What process can best answer your Questions about the vendor's data security safeguards?
Answer: B
Explanation:
This answer is the best process to answer Albert's questions about the vendor's data security safeguards, as it can provide a direct and comprehensive way to assess and verify the vendor's compliance with the applicable laws, regulations, standards and best practices for data protection. A second-party or supplier audit is conducted by the organization that hires or contracts the vendor to evaluate their performance and alignment with the organization's standards and expectations. A second-party or supplier audit can also help to identify any gaps, weaknesses or risks in the vendor's data security safeguards, and to recommend or require any improvements or corrective actions.
NEW QUESTION # 184
SCENARIO
Please use the following to answer the next QUESTION:
Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner, Anton, has found some degree of disorganization after touring the company headquarters. His uncle Henry had always focused on production - not data processing - and Anton is concerned. In several storage rooms, he has found paper files, disks, and old computers that appear to contain the personal data of current and former employees and customers. Anton knows that a single break-in could irrevocably damage the company's relationship with its loyal customers. He intends to set a goal of guaranteed zero loss of personal information.
To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of the company. However, Kenneth - his uncle's vice president and longtime confidante - wants to hold off on Anton's idea in favor of converting any paper records held at the company to electronic storage. Kenneth believes this process would only take one or two years. Anton likes this idea; he envisions a password- protected system that only he and Kenneth can access.
Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier, but it will simplify the management of the stored dat a. The heads of subsidiaries like the art gallery and kitchenware store down the street will be responsible for their own information management. Then, any unneeded subsidiary data still in Anton's possession can be destroyed within the next few years.
After learning of a recent security incident, Anton realizes that another crucial step will be notifying customers. Kenneth insists that two lost hard drives in Question are not cause for concern; all of the data was encrypted and not sensitive in nature. Anton does not want to take any chances, however. He intends on sending notice letters to all employees and customers to be safe.
Anton must also check for compliance with all legislative, regulatory, and market requirements related to privacy protection. Kenneth oversaw the development of the company's online presence about ten years ago, but Anton is not confident about his understanding of recent online marketing laws. Anton is assigning another trusted employee with a law background the task of the compliance assessment. After a thorough analysis, Anton knows the company should be safe for another five years, at which time he can order another check.
Documentation of this analysis will show auditors due diligence.
Anton has started down a long road toward improved management of the company, but he knows the effort is worth it. Anton wants his uncle's legacy to continue for many years to come.
Which of Anton's plans for improving the data management of the company is most unachievable?
Answer: C
Explanation:
Anton's objective for zero loss of personal information is the most unachievable among his plans for improving the data management of the company. While this objective is admirable and desirable, it is unrealistic and impractical to guarantee that no personal information will ever be lost due to a data breach or incident. Data breaches are inevitable and unpredictable events that can affect any organization regardless of its size or industry4 Even with the best data security practices and tools in place, there is always a possibility of human error, system failure, malicious attack, or natural disaster that could compromise personal information5 Therefore, Anton should focus on minimizing the likelihood and impact of data breaches rather than aiming for zero loss of personal information. He should also prepare a data breach response plan that outlines how to detect, contain, assess, report, and recover from a data breach in a timely and effective manner6 Reference: 4: [Data Breaches Are Inevitable: Here's How to Protect Your Business]; 5: The Top 5 Causes Of Data Breaches; 6: Data Breach Response: A Guide for Business - Federal Trade Commission
NEW QUESTION # 185
What is one reason the European Union has enacted more comprehensive privacy laws than the United States?
Answer: A
Explanation:
One reason the European Union has enacted more comprehensive privacy laws than the United States is to allow the free movement of data between member countries. The EU considers data protection as a fundamental right that applies to all individuals within its territory, regardless of their nationality or residence. The EU has adopted a harmonized legal framework for data protection, such as the GDPR1 and the ePrivacy Directive5, that applies to all member states and ensures a consistent level of protection across the EU. The EU also requires that any transfers of personal data outside the EU are subject to adequate safeguards or exceptions that guarantee an equivalent level of protection. The EU's approach to data protection aims to facilitate the internal market and promote economic and social integration among member states by removing barriers and restrictions to the cross-border flow of data. The other options are not reasons why the EU has enacted more comprehensive privacy laws than the US. The EU does not necessarily have more adequate enforcement or funding for its privacy laws than the US, although it does have a network of independent supervisory authorities that monitor and enforce compliance with the EU data protection rules. The EU does not allow separate industries to set privacy standards, but rather imposes uniform and binding rules for all sectors and activities that involve personal data processing. Reference: GDPR; ePrivacy Directive
NEW QUESTION # 186
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!" You want to point out that normal protocols have NOT been followed in this matter. Which process in particular has been neglected?
Answer: C
Explanation:
This answer is the best way to point out that normal protocols have not been followed in this matter, as it shows that the vendor selection process was not conducted properly and that the vendor's privacy and security practices were not assessed or verified before engaging them for the app development project. Vendor due diligence vetting is a process that involves evaluating and comparing potential vendors based on their qualifications, capabilities, reputation, experience, performance and compliance with the organization's standards and expectations, as well as the applicable laws and regulations. Vendor due diligence vetting can help to ensure that the vendor can deliver the project on time, on budget and on quality, as well as protect the personal data that they process on behalf of the organization. Vendor due diligence vetting can also help to identify and mitigate any risks or issues that may arise from the vendor relationship, such as data breaches, legal actions, fines, sanctions or investigations. References: IAPP CIPM Study Guide, page 821; ISO/IEC
27002:2013, section 15.1.1
NEW QUESTION # 187
What should a privacy professional keep in mind when selecting which metrics to collect?
Answer: D
Explanation:
Explanation/Reference:
NEW QUESTION # 188
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