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| Section | Objectives |
|---|---|
| Topic 1: Protecting Personal Data | - Handle cross-border data transfers - Implement privacy and security controls - Manage data subject rights |
| Topic 2: Developing a Framework | - Identify applicable laws and frameworks - Establish privacy governance structure - Define program scope and stakeholders |
| Topic 3: Establishing Governance | - Create privacy policies and procedures - Establish reporting mechanisms - Define roles and responsibilities |
| Topic 4: Sustaining Program Performance | - Monitor and audit privacy program - Implement continuous improvement - Measure program effectiveness |
| Topic 5: Assessing Data | - Perform privacy impact assessments - Manage vendor and third-party risks - Conduct data inventory and mapping |
| Topic 6: Responding to Requests and Incidents | - Handle data subject requests - Coordinate with regulators - Manage data breaches and incidents |
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NEW QUESTION # 71
SCENARIO
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 notification, which of the following would be the greatest concern?
Answer: B
Explanation:
Explanation
This answer is the greatest concern regarding the notification, as it violates the data minimization principle and exposes the affected individuals to further privacy and security risks. Collecting more personally identifiable information than necessary to provide updates to the affected individuals means that the company is asking for their name, email address, and month and year of birth, which may not be relevant or proportionate for the purpose of sending email notifications. Collecting more information than necessary can also increase the likelihood of data breaches, identity theft, fraud, or misuse of the data by unauthorized or malicious parties.
NEW QUESTION # 72
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 process could most effectively be used to add privacy protections to a new, comprehensive program being developed at Consolidated?
Answer: D
NEW QUESTION # 73
An executive for a multinational online retail company in the United States is looking for guidance in developing her company's privacy program beyond what is specifically required by law.
What would be the most effective resource for the executive to consult?
Answer: A
Explanation:
Industry frameworks are the most effective resource for an executive who wants to develop her company's privacy program beyond what is specifically required by law. Industry frameworks are collections of best practices, standards, and guidelines that help organizations establish and improve their privacy policies and procedures. Industry frameworks can help organizations demonstrate their commitment to privacy, enhance their reputation and trustworthiness, and comply with multiple privacy regulations. Some examples of industry frameworks are the NIST Privacy Framework2, the ISO 27701 Privacy Information Management System3, and the AICPA/CICA Generally Accepted Privacy Principles (GAPP)4. The other options are not as effective as industry frameworks for developing a privacy program. Internal auditors can help evaluate the effectiveness and compliance of existing privacy controls, but they may not provide guidance on how to improve or expand them. Oversight organizations can enforce privacy laws and regulations, but they may not offer advice on how to go beyond the legal requirements. Breach notifications from competitors can alert organizations to potential threats and vulnerabilities, but they may not suggest how to prevent or mitigate them. References: NIST Privacy Framework; ISO 27701 Privacy Information Management System; AICPA
/CICA Generally Accepted Privacy Principles (GAPP)
NEW QUESTION # 74
A "right to erasure" request could be rejected if the processing of personal data is for?
Answer: C
NEW QUESTION # 75
When building a data privacy program, what is a good starting point to understand the scope of privacy program needs?
Answer: D
NEW QUESTION # 76
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