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| Section | Objectives |
|---|---|
| Sustaining Program Performance | - Monitor and audit privacy program - Measure program effectiveness - Implement continuous improvement |
| Establishing Governance | - Define roles and responsibilities - Establish reporting mechanisms - Create privacy policies and procedures |
| Protecting Personal Data | - Manage data subject rights - Implement privacy and security controls - Handle cross-border data transfers |
| Responding to Requests and Incidents | - Manage data breaches and incidents - Coordinate with regulators - Handle data subject requests |
| Assessing Data | - Conduct data inventory and mapping - Manage vendor and third-party risks - Perform privacy impact assessments |
| Developing a Framework | - Identify applicable laws and frameworks - Establish privacy governance structure - Define program scope and stakeholders |
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NEW QUESTION # 194
What is the main purpose of a privacy program audit?
Answer: C
NEW QUESTION # 195
Under the General Data Protection Regulation (GDPR), what must be included in a written agreement between the controller and processor in relation to processing conducted on the controller's behalf?
Answer: A
Explanation:
Explanation
Under the GDPR, a written agreement between the controller and processor in relation to processing conducted on the controller's behalf must include an obligation on the processor to assist the controller in complying with the controller's obligations to notify the supervisory authority about personal data breaches.
This is one of the requirements under Article 28(3)(f) of the GDPR, which specifies the minimum content of such an agreement. The other options are not required by the GDPR, although they may be agreed upon by the parties as additional terms. References: GDPR, Article 28(3)(f).
NEW QUESTION # 196
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.
Which of the following was done CORRECTLY during the above incident?
Answer: A
Explanation:
Explanation
This answer is the only thing that was done correctly during the incident, as it shows a good practice of learning from and improving on the incident response process. The speed at which you sat down to reflect and document the incident means that you did not delay or postpone this important step, which can help you to capture and analyze what went well and what could have gone better during the incident, as well as to identify any lessons learned, best practices or recommendations for future incidents. Documenting and reflecting on the incident can also help you to update and improve your privacy policies, procedures and safeguards, as well as to demonstrate your accountability and compliance with any legal or contractual obligations.
NEW QUESTION # 197
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: C
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. Reference: NIST Privacy Framework; ISO 27701 Privacy Information Management System; AICPA/CICA Generally Accepted Privacy Principles (GAPP)
NEW QUESTION # 198
SCENARIO
Please use the following to answer the next QUESTION:
As they company's new chief executive officer, Thomas Goddard wants to be known as a leader in data protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically Questionable practices, including unauthorized sales of personal data to marketers. Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company's claims that "appropriate" data protection safeguards were in place. The scandal affected the company's business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard's mentor, was forced to step down.
Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company's board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures.
He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. "We want Medialite to have absolutely the highest standards," he says. "In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company's finances. So, while I want the best solutions across the board, they also need to be cost effective." You are told to report back in a week's time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.
You give a presentation to your CEO about privacy program maturity. What does it mean to have a "managed" privacy program, according to the AICPA/CICA Privacy Maturity Model?
Answer: B
NEW QUESTION # 199
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