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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Establishing Program Governance | 17–22% | - Accountability and oversight mechanisms - Policies, procedures and standards - Stakeholder engagement and communication - Training and awareness programs |
| Topic 2: Developing a Privacy Program Framework | 15–20% | - Program governance structure and roles - Legal and regulatory requirements - Program scope and boundaries - Privacy vision, strategy and objectives |
| Topic 3: Assessing Data and Privacy Risks | 17–22% | - Data inventory and mapping - Risk identification, analysis and mitigation - Compliance gap analysis - Privacy impact assessments (PIA/DPIA) |
| Topic 4: Protecting Personal Data | 12–18% | - Privacy by design and default - Data lifecycle management - Cross-border data transfers - Technical and organizational safeguards |
| Topic 5: Responding to Requests and Incidents | 14–18% | - Privacy incident response plan - Breach detection, notification and remediation - Regulatory interaction and reporting - Data subject rights management |
| Topic 6: Sustaining Program Performance | 10–15% | - Continuous improvement - Change management - Performance metrics and KPIs - Monitoring, auditing and reporting |
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NEW QUESTION # 129
What is the name for the privacy strategy model that describes delegated decision making?
Answer: A
Explanation:
Explanation
A matrix is a type of organizational structure that involves delegated decision making. In a matrix structure, employees report to more than one manager or leader, usually based on different functions or projects. For example, a software developer may report to both a product manager and a technical manager. A matrix structure allows for more flexibility, collaboration, and innovation in complex and dynamic environments.
The other options are not examples of delegated decision making structures. A de-centralized structure involves distributing decision making authority across different levels or units of the organization, rather than concentrating it at the top. A de-functionalized structure involves breaking down functional silos and creating cross-functional teams or processes. A hybrid structure involves combining elements of different types of structures, such as functional, divisional, or matrix.
NEW QUESTION # 130
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: A
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 # 131
All of the following changes will likely trigger a data inventory update EXCEPT?
Answer: A
NEW QUESTION # 132
SCENARIO
Please use the following to answer the next QUESTION:
Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can be used in the home to manage family calendars, do online shopping, and schedule doctor appointments.
After having had a successful launch in the United States, the Handy Helper is about to be made available for purchase worldwide.
The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the whole family, including children, but does not provide any further detail or privacy notice. In order to use the application, a family creates a single account, and the primary user has access to all information about the other users. Upon start up, the primary user must check a box consenting to receive marketing emails from Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.
Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European distributor of Handy Helper when he fielded many Questions about the product from the distributor. Sanjay needed to look more closely at the product in order to be able to answer the Questions as he was not involved in the product development process.
In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the product. This data is all stored in the cloud and is encrypted both during transmission and at rest.
Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent Omnimedia employees have access to user data under a program called Eureka. Omnipresent Omnimedia is hoping that at some point in the future, the data will reveal insights that could be used to create a fully automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is considered a long-term goal.
What administrative safeguards should be implemented to protect the collected data while in use by Manasa and her product management team?
Answer: B
Explanation:
Explanation
An administrative safeguard that should be implemented to protect the collected data while in use by Manasa and her product management team is a policy restricting data access on a "need to know" basis. This means that only authorized personnel who have a legitimate business purpose for accessing the data should be able to do so3 This would help to prevent unauthorized or unnecessary access, use, or disclosure of sensitive or personal data by internal or external parties. It would also reduce the risk of data breaches, theft, or loss that could compromise the confidentiality, integrity, and availability of the data4 References: 3: HIPAA Security Series #2 - Administrative Safeguards - HHS.gov; 4: Administrative Safeguards of the Security Rule: What Are They?
NEW QUESTION # 133
What is one obligation that the General Data Protection Regulation (GDPR) imposes on data processors?
Answer: D
Explanation:
Explanation/Reference: https://www.whitecase.com/publications/article/chapter-12-impact-assessments-dpos-and-codes- conduct-unlocking-eu-general-data
NEW QUESTION # 134
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