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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Developing a Privacy Program Framework | 15–20% | - Program scope and boundaries - Privacy vision, strategy and objectives - Legal and regulatory requirements - Program governance structure and roles |
| Topic 2: Responding to Requests and Incidents | 14–18% | - Regulatory interaction and reporting - Privacy incident response plan - Data subject rights management - Breach detection, notification and remediation |
| Topic 3: Establishing Program Governance | 17–22% | - Policies, procedures and standards - Training and awareness programs - Stakeholder engagement and communication - Accountability and oversight mechanisms |
| Topic 4: Sustaining Program Performance | 10–15% | - Change management - Monitoring, auditing and reporting - Continuous improvement - Performance metrics and KPIs |
| Topic 5: Assessing Data and Privacy Risks | 17–22% | - Risk identification, analysis and mitigation - Privacy impact assessments (PIA/DPIA) - Compliance gap analysis - Data inventory and mapping |
| Topic 6: Protecting Personal Data | 12–18% | - Cross-border data transfers - Privacy by design and default - Technical and organizational safeguards - Data lifecycle management |
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NEW QUESTION # 216
SCENARIO
Please use the following to answer the next QUESTION:
As the Director of data protection for Consolidated Records Corporation, you are justifiably pleased with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of relatively minor data breaches that could easily have been worse. However, you have not had a reportable incident for the three years that you have been with the company. In fact, you consider your program a model that others in the data storage industry may note in their own program development.
You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward coherence across departments and throughout operations. You were aided along the way by the program's sponsor, the vice president of operations, as well as by a Privacy Team that started from a clear understanding of the need for change.
Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard" among both the executive team and frontline personnel working with data and interfacing with clients. Through the use of metrics that showed the costs not only of the breaches that had occurred, but also projections of the costs that easily could occur given the current state of operations, you soon had the leaders and key decision-makers largely on your side. Many of the other employees were more resistant, but face-to-face meetings with each department and the development of a baseline privacy training program achieved sufficient "buy-in" to begin putting the proper procedures into place.
Now, privacy protection is an accepted component of all current operations involving personal or protected data and must be part of the end product of any process of technological development. While your approach is not systematic, it is fairly effective.
You are left contemplating:
What must be done to maintain the program and develop it beyond just a data breach prevention program?
How can you build on your success?
What are the next action steps?
What practice would afford the Director the most rigorous way to check on the program's compliance with laws, regulations and industry best practices?
Answer: D
NEW QUESTION # 217
SCENARIO
Please use the following to answer the next QUESTION:
For 15 years, Albert has worked at Treasure Box - a mail order company in the United States (U.S.) that used to sell decorative candles around the world, but has recently decided to limit its shipments to customers in the
48 contiguous states. Despite his years of experience, Albert is often overlooked for managerial positions. His frustration about not being promoted, coupled with his recent interest in issues of privacy protection, have motivated Albert to be an agent of positive change.
He will soon interview for a newly advertised position, and during the interview, Albert plans on making executives aware of lapses in the company's privacy program. He feels certain he will be rewarded with a promotion for preventing negative consequences resulting from the company's outdated policies and procedures.
For example, Albert has learned about the AICPA (American Institute of Certified Public Accountans)/CICA (Canadian Institute of Chartered Accountants) Privacy Maturity Model (PMM). Albert thinks the model is a useful way to measure Treasure Box's ability to protect personal data. Albert has noticed that Treasure Box fails to meet the requirements of the highest level of maturity of this model; at his interview, Albert will pledge to assist the company with meeting this level in order to provide customers with the most rigorous security available.
Albert does want to show a positive outlook during his interview. He intends to praise the company's commitment to the security of customer and employee personal data against external threats. However, Albert worries about the high turnover rate within the company, particularly in the area of direct phone marketing. He sees many unfamiliar faces every day who are hired to do the marketing, and he often hears complaints in the lunch room regarding long hours and low pay, as well as what seems to be flagrant disregard for company procedures.
In addition, Treasure Box has had two recent security incidents. The company has responded to the incidents with internal audits and updates to security safeguards. However, profits still seem to be affected and anecdotal evidence indicates that many people still harbor mistrust. Albert wants to help the company recover.
He knows there is at least one incident the public in unaware of, although Albert does not know the details. He believes the company's insistence on keeping the incident a secret could be a further detriment to its reputation. One further way that Albert wants to help Treasure Box regain its stature is by creating a toll-free number for customers, as well as a more efficient procedure for responding to customer concerns by postal mail.
In addition to his suggestions for improvement, Albert believes that his knowledge of the company's recent business maneuvers will also impress the interviewers. For example, Albert is aware of the company's intention to acquire a medical supply company in the coming weeks.
With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the job.
Based on Albert's observations, executive leadership should most likely pay closer attention to what?
Answer: D
Explanation:
Explanation
This answer is the best suggestion that Albert should make based on his observations regarding recent security incidents, as it can help to ensure that Treasure Box's privacy program and practices are assessed and verified by an independent and objective party who has the necessary expertise, experience and credentials to evaluate the company's compliance with the applicable laws, regulations, standards and best practices for data protection. Using a third-party auditor can also help to identify any gaps, weaknesses or risks that may have been overlooked or missed by the prior internal audits, and to recommend or implement any improvements or corrective actions. A third-party audit can also help to enhance the company's reputation and trust among its customers, partners and stakeholders, as well as demonstrate its commitment and accountability for privacy protection.
NEW QUESTION # 218
What is the main reason to begin with 3-5 key metrics during the program development process?
Answer: C
NEW QUESTION # 219
Why were the nongovernmental privacy organizations, Electronic Frontier Foundation (EFF) and Electronic Privacy Information Center (EPIC), established?
Answer: C
Explanation:
Explanation
The nongovernmental privacy organizations, Electronic Frontier Foundation (EFF) and Electronic Privacy Information Center (EPIC), were established to protect civil liberties and raise consumer awareness in the digital age. Both organizations are public interest research centers that focus on emerging privacy and civil liberties issues and advocate for the protection of privacy, freedom of expression, and democratic values in the information age12 They conduct policy research, public education, litigation, publications, and advocacy to promote privacy rights and challenge threats to privacy from governments, corporations, or other actors12 They also monitor and participate in the development of laws, regulations, standards, and technologies that affect privacy and civil liberties12 References: 1: About EPIC; 2: About EFF
NEW QUESTION # 220
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 # 221
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