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| Section | Weight | Objectives |
|---|---|---|
| Protecting Personal Data | 12–18% | - Data lifecycle management - Technical and organizational safeguards - Cross-border data transfers - Privacy by design and default |
| Assessing Data and Privacy Risks | 17–22% | - Privacy impact assessments (PIA/DPIA) - Compliance gap analysis - Risk identification, analysis and mitigation - Data inventory and mapping |
| Responding to Requests and Incidents | 14–18% | - Privacy incident response plan - Data subject rights management - Regulatory interaction and reporting - Breach detection, notification and remediation |
| Establishing Program Governance | 17–22% | - Policies, procedures and standards - Accountability and oversight mechanisms - Training and awareness programs - Stakeholder engagement and communication |
| Sustaining Program Performance | 10–15% | - Monitoring, auditing and reporting - Change management - Continuous improvement - Performance metrics and KPIs |
| Developing a Privacy Program Framework | 15–20% | - Legal and regulatory requirements - Program governance structure and roles - Privacy vision, strategy and objectives - Program scope and boundaries |
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NEW QUESTION # 257
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 is the best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has?
Answer: B
NEW QUESTION # 258
SCENARIO
Please use the following to answer the next QUESTION:
Perhaps Jack Kelly should have stayed in the U.S. He enjoys a formidable reputation inside the company, Special Handling Shipping, for his work in reforming certain "rogue" offices. Last year, news broke that a police sting operation had revealed a drug ring operating in the Providence, Rhode Island office in the United States. Video from the office's video surveillance cameras leaked to news operations showed a drug exchange between Special Handling staff and undercover officers.
In the wake of this incident, Kelly had been sent to Providence to change the "hands off" culture that upper management believed had let the criminal elements conduct their illicit transactions. After a few weeks under Kelly's direction, the office became a model of efficiency and customer service. Kelly monitored his workers' activities using the same cameras that had recorded the illegal conduct of their former co-workers.
Now Kelly has been charged with turning around the office in Cork, Ireland, another trouble spot. The company has received numerous reports of the staff leaving the office unattended. When Kelly arrived, he found that even when present, the staff often spent their days socializing or conducting personal business on their mobile phones. Again, he observed their behaviors using surveillance cameras. He issued written reprimands to six staff members based on the first day of video alone.
Much to Kelly's surprise and chagrin, he and the company are now under investigation by the Data Protection Commissioner of Ireland for allegedly violating the privacy rights of employees. Kelly was told that the company's license for the cameras listed facility security as their main use, but he does not know why this matters. He has pointed out to his superiors that the company's training programs on privacy protection and data collection mention nothing about surveillance video.
You are a privacy protection consultant, hired by the company to assess this incident, report on the legal and compliance issues, and recommend next steps.
What should you advise this company regarding the status of security cameras at their offices in the United States?
Answer: D
Explanation:
This answer is the best way to advise this company regarding the status of security cameras at their offices in the United States, as it can help to protect the privacy and security of the employees and visitors who are recorded by the cameras, as well as to comply with any applicable laws and regulations that may limit or regulate the use of surveillance video. Restricting access to surveillance video means that only authorized personnel who have a legitimate business need can view, copy, share or disclose the video, and that they must follow proper procedures and safeguards to prevent unauthorized or unlawful access, use or disclosure.
Destroying the recordings after a designated period of time means that the video is not kept longer than necessary for the purpose for which it was collected, and that it is disposed of securely and irreversibly. The designated period of time should be based on the legal, operational and risk factors that may affect the retention of the video, such as potential litigation, investigations, audits or claims. References: IAPP CIPM Study Guide, page 831; ISO/IEC 27002:2013, section 8.3.2
NEW QUESTION # 259
When devising effective employee policies to address a particular issue, which of the following should be included in the first draft?
Answer: B
Explanation:
When devising effective employee policies to address a particular issue, it is important to include the rationale for the policy in the first draft, as it explains why the policy is needed and what benefits it brings to the organization and its employees. The rationale can also help to gain support and buy-in from the management and staff, as well as to align the policy with the organizational values and goals. The other options are also important elements of an employee policy, but they can be added or refined in later drafts. Reference: CIPM Body of Knowledge, Domain IV: Privacy Program Communication Activities, Task 2: Develop internal communication plans.
NEW QUESTION # 260
What is most critical when outsourcing data destruction service?
Answer: D
Explanation:
Obtaining a certificate of data destruction is the most critical step when outsourcing data destruction service.
Data destruction is the process of permanently erasing or destroying personal information from electronic devices or media so that it cannot be recovered or reconstructed. Data destruction is an important part of data protection and retention policies, as it helps prevent unauthorized access, disclosure, or misuse of personal information that is no longer needed or relevant. Outsourcing data destruction service can be convenient and cost-effective for an organization that does not have the resources or expertise to perform it in-house.
However, outsourcing also involves transferring personal information to a third-party provider that may not have the same level of security or accountability as the organization. Therefore, obtaining a certificate of data destruction from the provider is essential to verify that the data destruction has been performed according to the agreed standards and specifications, and that no copies or backups have been retained by the provider. A certificate of data destruction should include information such as: the date and time of the data destruction; the method and level of the data destruction; the serial numbers or identifiers of the devices or media; the name and signature of the person who performed the data destruction; and any relevant laws or regulations that apply to the data destruction.
References:
CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle Section B:
Protecting Personal Information Subsection 4: Data Retention
CIPM Study Guide (2021), Chapter 8: Protecting Personal Information Section 8.4: Data Retention CIPM Textbook (2019), Chapter 8: Protecting Personal Information Section 8.4: Data Retention CIPM Practice Exam (2021), Question 149
NEW QUESTION # 261
SCENARIO
Please use the following to answer the next QUESTION:
Richard McAdams recently graduated law school and decided to return to the small town of Lexington, Virginia to help run his aging grandfather's law practice. The elder McAdams desired a limited, lighter role in the practice, with the hope that his grandson would eventually take over when he fully retires. In addition to hiring Richard, Mr. McAdams employs two paralegals, an administrative assistant, and a part-time IT specialist who handles all of their basic networking needs. He plans to hire more employees once Richard gets settled and assesses the office's strategies for growth.
Immediately upon arrival, Richard was amazed at the amount of work that needed to done in order to modernize the office, mostly in regard to the handling of clients' personal data. His first goal is to digitize all the records kept in file cabinets, as many of the documents contain personally identifiable financial and medical data. Also, Richard has noticed the massive amount of copying by the administrative assistant throughout the day, a practice that not only adds daily to the number of files in the file cabinets, but may create security issues unless a formal policy is firmly in place Richard is also concerned with the overuse of the communal copier/ printer located in plain view of clients who frequent the building. Yet another area of concern is the use of the same fax machine by all of the employees. Richard hopes to reduce its use dramatically in order to ensure that personal data receives the utmost security and protection, and eventually move toward a strict Internet faxing policy by the year's end.
Richard expressed his concerns to his grandfather, who agreed, that updating data storage, data security, and an overall approach to increasing the protection of personal data in all facets is necessary Mr. McAdams granted him the freedom and authority to do so. Now Richard is not only beginning a career as an attorney, but also functioning as the privacy officer of the small firm. Richard plans to meet with the IT employee the following day, to get insight into how the office computer system is currently set-up and managed.
Richard believes that a transition from the use of fax machine to Internet faxing provides all of the following security benefits EXCEPT?
Answer: D
NEW QUESTION # 262
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