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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Privacy Program Governance | 50% | - Stakeholder engagement and communication - Metrics, reporting, and accountability - Privacy program structure and governance models - Policy development and implementation |
| Topic 2: Operational Life Cycle of a Privacy Program | 50% | - Implementing privacy controls and procedures - Assessing privacy risks and impacts - Monitoring, auditing, and continuous improvement - Managing data inventory and data flows |
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NEW QUESTION # 30
SCENARIO
Please use the following to answer the next QUESTION:
Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new privacy officer. The company is based in California but thanks to some great publicity from a social media influencer last year, the company has received an influx of sales from the EU and has set up a regional office in Ireland to support this expansion. To become familiar with Ace Space's practices and assess what her privacy priorities will be, Penny has set up meetings with a number of colleagues to hear about the work that they have been doing and their compliance efforts.
Penny's colleague in Marketing is excited by the new sales and the company's plans, but is also concerned that Penny may curtail some of the growth opportunities he has planned. He tells her "I heard someone in the breakroom talking about some new privacy laws but I really don't think it affects us. We're just a small company. I mean we just sell accessories online, so what's the real risk?" He has also told her that he works with a number of small companies that help him get projects completed in a hurry. "We've got to meet our deadlines otherwise we lose money. I just sign the contracts and get Jim in finance to push through the payment. Reviewing the contracts takes time that we just don't have." In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken a number of precautions to protect its website from malicious activity, it has not taken the same level of care of its physical files or internal infrastructure. Penny's colleague in IT has told her that a former employee lost an encrypted USB key with financial data on it when he left. The company nearly lost access to their customer database last year after they fell victim to a phishing attack. Penny is told by her IT colleague that the IT team
"didn't know what to do or who should do what. We hadn't been trained on it but we're a small team though, so it worked out OK in the end." Penny is concerned that these issues will compromise Ace Space's privacy and data protection.
Penny is aware that the company has solid plans to grow its international sales and will be working closely with the CEO to give the organization a data "shake up". Her mission is to cultivate a strong privacy culture within the company.
Penny has a meeting with Ace Space's CEO today and has been asked to give her first impressions and an overview of her next steps.
What information will be LEAST crucial from a privacy perspective in Penny's review of vendor contracts?
Answer: A
Explanation:
The information that will be least crucial from a privacy perspective in Penny's review of vendor contracts is the pricing for data security protections . This is because the pricing for data security protections is a business decision that does not directly affect the privacy rights and obligations of Ace Space and its customers. The pricing for data security protections may be relevant for budgeting and negotiating purposes, but it does not determine the level or adequacy of data security measures that the vendor must provide to protect personal data.
The other options are more crucial from a privacy perspective in Penny's review of vendor contracts. Audit rights (A) are important to ensure that Ace Space can monitor and verify the vendor's compliance with the contract terms and the applicable privacy laws and regulations. Audit rights allow Ace Space to access the vendor's records, systems, policies and procedures related to personal data processing and to conduct inspections or assessments as needed. Liability for a data breach (B) is important to allocate the responsibility and consequences of a data breach involving personal data that the vendor processes on behalf of Ace Space.
Liability for a data breach may include indemnification, compensation, notification, remediation and termination clauses that protect Ace Space's interests and obligations in the event of a data breach. The data a vendor will have access to (D) is important to define the scope, purpose, duration and conditions of the personal data processing that the vendor will perform for Ace Space. The data a vendor will have access to may include the categories, types, sources, recipients and retention periods of personal data that the vendor will collect, store, use or share on behalf of Ace Space.
References:
CIPM Body of Knowledge Domain II: Privacy Program Operational Life Cycle - Task 3: Implement privacy program components - Subtask 3: Establish third-party processor management program CIPM Study Guide - Chapter 4: Privacy Program Operational Life Cycle - Section 4.3: Third-Party Processor Management
NEW QUESTION # 31
Formosa International operates in 20 different countries including the United States and France.
What organizational approach would make complying with a number of different regulations easier?
Answer: B
NEW QUESTION # 32
When developing a privacy program and selecting a program sponsor or "champion" the least important consideration should be that they?
Answer: A
NEW QUESTION # 33
Under the General Data Protection Regulation (GDPR), which of the following situations would LEAST likely require a controller to notify a data subject?
Answer: C
Explanation:
Under the GDPR, a controller must notify a data subject of a personal data breach without undue delay when the breach is likely to result in a high risk to the rights and freedoms of the data subject, unless one of the following conditions applies: the personal data are rendered unintelligible to any person who is not authorized to access it, such as by encryption; the controller has taken subsequent measures to ensure that the high risk is no longer likely to materialize; or the notification would involve disproportionate effort, in which case a public communication or similar measure may suffice. In this case, an encrypted USB key with sensitive personal data is stolen, but the personal data are presumably unintelligible to the thief, so the controller does not need to notify the data subject. However, the controller still needs to notify the supervisory authority within 72 hours of becoming aware of the breach, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons.
References:
CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section B:
Protecting Personal Information, Subsection 2: Data Breach Incident Planning and Management CIPM Study Guide (2021), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management CIPM Textbook (2019), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management CIPM Practice Exam (2021), Question 134 GDPR Article 33 and 3412
NEW QUESTION # 34
Your company wants to convert paper records that contain customer personal information into electronic form, upload the records into a new third-party marketing tool and then merge the customer personal information in the marketing tool with information from other applications.
As the Privacy Officer, which of the following should you complete to effectively make these changes?
Answer: D
Explanation:
Explanation
A Privacy Impact Assessment (PIA) is a process that helps an organization identify and evaluate the potential privacy risks and impacts of a new or existing project, program, system, or service that involves the collection, use, disclosure, or retention of personal information. A PIA also helps an organization identify and implement appropriate measures to mitigate or eliminate those risks and impacts, and ensure compliance with applicable privacy laws, regulations, and standards. A PIA should be completed to effectively make changes that involve customer personal information, such as converting paper records into electronic form, uploading the records into a new third-party marketing tool, and merging the customer personal information in the marketing tool with information from other applications. A PIA can help an organization assess the necessity, proportionality, and legality of the proposed changes, as well as the potential privacy risks to the customers and the organization, such as unauthorized access, disclosure, modification, or loss of personal information, identity theft, fraud, reputational damage, or legal liability. A PIA can also help an organization implement appropriate measures to mitigate or eliminate those risks, such as data minimization, encryption, anonymization, pseudonymization, consent management, access control, security safeguards, contractual clauses, data protection impact assessments (DPIAs), data subject rights, breach notification procedures, and privacy policies.
References:
* CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section C:
Monitoring and Managing Program Performance Subsection 1: Privacy Impact Assessments1
* CIPM Study Guide (2021), Chapter 9: Monitoring and Managing Program Performance Section 9.1:
Privacy Impact Assessments2
* CIPM Textbook (2019), Chapter 9: Monitoring and Managing Program Performance Section 9.1:
Privacy Impact Assessments3
* CIPM Practice Exam (2021), Question 1464
NEW QUESTION # 35
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