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| Section | Objectives |
|---|---|
| Topic 1: Developing a Framework | - Define program scope and stakeholders - Identify applicable laws and frameworks - Establish privacy governance structure |
| Topic 2: Assessing Data | - Manage vendor and third-party risks - Conduct data inventory and mapping - Perform privacy impact assessments |
| Topic 3: Sustaining Program Performance | - Implement continuous improvement - Measure program effectiveness - Monitor and audit privacy program |
| Topic 4: Responding to Requests and Incidents | - Handle data subject requests - Manage data breaches and incidents - Coordinate with regulators |
| Topic 5: Protecting Personal Data | - Implement privacy and security controls - Manage data subject rights - Handle cross-border data transfers |
| Topic 6: Establishing Governance | - Establish reporting mechanisms - Define roles and responsibilities - Create privacy policies and procedures |
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79. Frage
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 Eurek a. 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 can Sanjay do to minimize the risks of offering the product in Europe?
Antwort: B
80. Frage
Why were the nongovernmental privacy organizations, Electronic Frontier Foundation (EFF) and Electronic Privacy Information Center (EPIC), established?
Antwort: B
Begründung:
The nongovernmental privacy organizations, Electronic Frontier Foundation (EFF) and Electronic Privacy Information Center (EPIC), were established to protect civil liberties and raise consumer awareness in the digital age. Both organizations are public interest research centers that focus on emerging privacy and civil liberties issues and advocate for the protection of privacy, freedom of expression, and democratic values in the information age12 They conduct policy research, public education, litigation, publications, and advocacy to promote privacy rights and challenge threats to privacy from governments, corporations, or other actors12 They also monitor and participate in the development of laws, regulations, standards, and technologies that affect privacy and civil liberties12 References: 1: About EPIC; 2: About EFF Reference: https://en.wikipedia.org/wiki/Electronic_Privacy_Information_Center
81. Frage
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 Eurek a. 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 element of the Privacy by Design (PbD) framework might the Handy Helper violate?
Antwort: C
Begründung:
The Handy Helper might violate the element of the Privacy by Design (PbD) framework that requires integrating privacy throughout the system development life cycle. According to the PbD framework, privacy should be embedded into the design and architecture of IT systems and business practices, not added as an afterthought1 This means that privacy should be considered at every stage of the system development life cycle, from planning to analysis to design to development to implementation to maintenance2 However, the Handy Helper seems to have been developed without involving Sanjay, the head of privacy, or conducting a privacy impact assessment (PIA) to identify and mitigate potential privacy risks3 The product also lacks a clear and transparent privacy notice that informs users about what data is collected, how it is used, where it is stored, who has access to it, and what choices they have4 These issues could expose the product to legal and reputational challenges, especially in regions with strict data protection regulations, such as Europe. Reference: 1: Privacy by Design - The LIFE Institute; 2: System Development Life Cycle - GeeksforGeeks; 3: [Privacy Impact Assessment (PIA) | NZ Digital government]; 4: [Privacy Notices under EU Data Protection Law | Privacy International]
82. Frage
What should a privacy professional keep in mind when selecting which metrics to collect?
Antwort: D
Begründung:
Explanation/Reference:
83. Frage
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.
How could the objection to Spencer's training suggestion be addressed?
Antwort: A
Begründung:
This answer is the best way to address the objection to Spencer's training suggestion, as it can provide flexibility and convenience for employees who work in different locations or have different schedules. Alternative delivery methods for trainings can include online courses, webinars, podcasts, videos or self-paced modules that can be accessed anytime and anywhere by employees. Alternative delivery methods can also reduce the cost and time required for in-person trainings, while still ensuring that employees receive consistent and relevant information on the company's privacy program. Reference: IAPP CIPM Study Guide, page 90; ISO/IEC 27002:2013, section 7.2.2
84. Frage
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