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| Section | Objectives |
|---|---|
| Assessing Data | - Conduct data inventory and mapping - Manage vendor and third-party risks - Perform privacy impact assessments |
| Responding to Requests and Incidents | - Handle data subject requests - Coordinate with regulators - Manage data breaches and incidents |
| Protecting Personal Data | - Handle cross-border data transfers - Manage data subject rights - Implement privacy and security controls |
| Establishing Governance | - Create privacy policies and procedures - Define roles and responsibilities - Establish reporting mechanisms |
| Sustaining Program Performance | - Implement continuous improvement - Monitor and audit privacy program - Measure program effectiveness |
| Developing a Framework | - Identify applicable laws and frameworks - Establish privacy governance structure - Define program scope and stakeholders |
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NEW QUESTION # 211
Under the General Data Protection Regulation (GDPR), which situation would be LEAST likely to require a Data Protection Impact Assessment (DPIA)?
Answer: C
Explanation:
A Data Protection Impact Assessment (DPIA) is a process to help identify and minimize the data protection risks of a project. Under the GDPR, a DPIA is required when the processing is likely to result in a high risk to the rights and freedoms of individuals, especially when using new technologies. The GDPR provides some examples of high-risk processing activities, such as systematic and extensive evaluation of personal aspects, large-scale processing of special categories of data, or systematic monitoring of public areas. The other options are more likely to require a DPIA than the online magazine using a mailing list to send a generic daily digest to marketing emails, as they involve more sensitive or intrusive types of processing. References:
* [Data protection impact assessments | ICO]
* [Art. 35 GDPR - Data protection impact assessment - GDPR.eu]
NEW QUESTION # 212
What is the main purpose in notifying data subjects of a data breach?
Answer: D
Explanation:
The main purpose in notifying data subjects of a data breach is to allow individuals to take any actions required to protect themselves from possible consequences, such as identity theft, fraud, or discrimination.
This is consistent with the principle of transparency and the right to information under the GDPR. The other options are not the main purpose of notification, although they may be secondary effects or benefits of the process. References:
* Data protection impact assessments | ICO
* [Art. 34 GDPR - Communication of a personal data breach to the data subject - GDPR.eu]
NEW QUESTION # 213
SCENARIO
Please use the following to answer the next QUESTION:
Natalia, CFO of the Nationwide Grill restaurant chain, had never seen her fellow executives so anxious. Last week, a data processing firm used by the company reported that its system may have been hacked, and customer data such as names, addresses, and birthdays may have been compromised. Although the attempt was proven unsuccessful, the scare has prompted several Nationwide Grill executives to Question the company's privacy program at today's meeting.
Alice, a vice president, said that the incident could have opened the door to lawsuits, potentially damaging Nationwide Grill's market position. The Chief Information Officer (CIO), Brendan, tried to assure her that even if there had been an actual breach, the chances of a successful suit against the company were slim. But Alice remained unconvinced.
Spencer - a former CEO and currently a senior advisor - said that he had always warned against the use of contractors for data processing. At the very least, he argued, they should be held contractually liable for telling customers about any security incidents. In his view, Nationwide Grill should not be forced to soil the company name for a problem it did not cause.
One of the business development (BD) executives, Haley, then spoke, imploring everyone to see reason.
"Breaches can happen, despite organizations' best efforts," she remarked. "Reasonable preparedness is key." She reminded everyone of the incident seven years ago when the large grocery chain Tinkerton's had its financial information compromised after a large order of Nationwide Grill frozen dinners. As a long-time BD executive with a solid understanding of Tinkerton's's corporate culture, built up through many years of cultivating relationships, Haley was able to successfully manage the company's incident response.
Spencer replied that acting with reason means allowing security to be handled by the security functions within the company - not BD staff. In a similar way, he said, Human Resources (HR) needs to do a better job training employees to prevent incidents. He pointed out that Nationwide Grill employees are overwhelmed with posters, emails, and memos from both HR and the ethics department related to the company's privacy program. Both the volume and the duplication of information means that it is often ignored altogether.
Spencer said, "The company needs to dedicate itself to its privacy program and set regular in-person trainings for all staff once a month." Alice responded that the suggestion, while well-meaning, is not practical. With many locations, local HR departments need to have flexibility with their training schedules. Silently, Natalia agreed.
What is the most realistic step the organization can take to help diminish liability in the event of another incident?
Answer: B
Explanation:
This answer is the most realistic step the organization can take to help diminish liability in the event of another incident, as it can ensure that the vendor complies with the same standards and obligations as the organization regarding data protection. Vendor contracts should include clauses that specify the scope, purpose, duration and type of data processing, as well as the rights and responsibilities of both parties. The contracts should also require the vendor to implement appropriate technical and organizational measures to protect the data from unauthorized or unlawful access, use, disclosure, alteration or destruction, and to notify the organization of any security incidents or breaches. The contracts should also allow the organization to monitor, audit or inspect the vendor's performance and compliance with the contract terms and applicable laws and regulations. References: IAPP CIPM Study Guide, page 82; ISO/IEC 27002:2013, section 15.1.2
NEW QUESTION # 214
What should be the first major goal of a company developing a new privacy program?
Answer: C
Explanation:
Explanation
The first major goal of a company developing a new privacy program should be to schedule conversations with executives of affected departments. This is because a privacy program requires the support and involvement of senior management and key stakeholders from different business units, such as legal, IT, marketing, human resources, etc. By engaging with them early on, a privacy professional can understand their needs, expectations, challenges, and risks, and align the privacy program objectives and strategies with the organization's goals and culture. References: [How to Develop a Privacy Program], [Privacy Program Management]
NEW QUESTION # 215
SCENARIO
Please use the following to answer the next QUESTION:
John is the new privacy officer at the prestigious international law firm - A&M LLP. A&M LLP is very proud of its reputation in the practice areas of Trusts & Estates and Merger & Acquisition in both U.S. and Europe.
During lunch with a colleague from the Information Technology department, John heard that the Head of IT, Derrick, is about to outsource the firm's email continuity service to their existing email security vendor - MessageSafe. Being successful as an email hygiene vendor, MessageSafe is expanding its business by leasing cloud infrastructure from Cloud Inc. to host email continuity service for A&M LLP.
John is very concerned about this initiative. He recalled that MessageSafe was in the news six months ago due to a security breach. Immediately, John did a quick research of MessageSafe's previous breach and learned that the breach was caused by an unintentional mistake by an IT administrator. He scheduled a meeting with Derrick to address his concerns.
At the meeting, Derrick emphasized that email is the primary method for the firm's lawyers to communicate with clients, thus it is critical to have the email continuity service to avoid any possible email downtime. Derrick has been using the anti-spam service provided by MessageSafe for five years and is very happy with the quality of service provided by MessageSafe. In addition to the significant discount offered by MessageSafe, Derrick emphasized that he can also speed up the onboarding process since the firm already has a service contract in place with MessageSafe. The existing on-premises email continuity solution is about to reach its end of life very soon and he doesn't have the time or resource to look for another solution. Furthermore, the off-premises email continuity service will only be turned on when the email service at A&M LLP's primary and secondary data centers are both down, and the email messages stored at MessageSafe site for continuity service will be automatically deleted after 30 days.
Which of the following is the most effective control to enforce MessageSafe's implementation of appropriate technical countermeasures to protect the personal data received from A&M LLP?
Answer: C
Explanation:
The most effective control to enforce MessageSafe's implementation of appropriate technical countermeasures to protect the personal data received from A&M LLP is to require MessageSafe to apply appropriate security controls on the cloud infrastructure. This control ensures that MessageSafe takes responsibility for securing the personal data that it processes on behalf of A&M LLP on the cloud platform provided by Cloud Inc. According to the GDPR, data processors must implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of processing personal data1 These measures may include encryption, pseudonymisation, access control, backup and recovery, logging and monitoring, vulnerability management, incident response, etc2 Furthermore, data processors must ensure that any sub-processors they engage to process personal data on behalf of the data controller also comply with the same obligations3 Therefore, MessageSafe must ensure that Cloud Inc. provides adequate security guarantees for the cloud infrastructure and services that it uses to host the email continuity service for A&M LLP. MessageSafe must also monitor and audit the security performance of Cloud Inc. and report any issues or breaches to A&M LLP. Reference: 1: Article 32 GDPR | General Data Protection Regulation (GDPR); 2: Guidelines 4/2019 on Article 25 Data Protection by Design and by Default | European Data Protection Board; 3: Article 28 GDPR | General Data Protection Regulation (GDPR)
NEW QUESTION # 216
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