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| Section | Objectives |
|---|---|
| Topic 1: Developing a Framework | - Establish privacy governance structure - Identify applicable laws and frameworks - Define program scope and stakeholders |
| Topic 2: Establishing Governance | - Establish reporting mechanisms - Define roles and responsibilities - Create privacy policies and procedures |
| Topic 3: Protecting Personal Data | - Handle cross-border data transfers - Implement privacy and security controls - Manage data subject rights |
| Topic 4: Assessing Data | - Perform privacy impact assessments - Conduct data inventory and mapping - Manage vendor and third-party risks |
| Topic 5: Responding to Requests and Incidents | - Handle data subject requests - Coordinate with regulators - Manage data breaches and incidents |
| Topic 6: Sustaining Program Performance | - Measure program effectiveness - Monitor and audit privacy program - Implement continuous improvement |
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質問 # 162
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?
正解：C
質問 # 163
(Your company's lead applied scientist believes there's an opportunity to proactively address customer issues using machine learning. She requests access to all of the company's customer data and several publicly available datasets. All the following are appropriate next steps EXCEPT?)
正解：C
解説：
The most appropriate early steps are toclarify purpose,scope, anddata needs(D), confirm whether current notices/lawful bases cover the proposed processing (C), and applydata minimization/anonymizationwhere possible (A). Jumping immediately to a broad public disclosure (B) is premature before confirming feasibility, lawful basis, necessity, proportionality, and whether the initiative will proceed as described. Transparency is essential, but it follows (and is informed by) the assessment of the actual processing design.
質問 # 164
You are the privacy officer at a university. Recently, the police have contacted you as they suspect that one of your students is using a library computer to commit financial fraud. The police would like your assistance in investigating this individual and are requesting computer logs and usage data of the student.
What Is your first step in responding to the request?
正解：C
質問 # 165
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?
正解：B
解説：
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. References: 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)
質問 # 166
Your company's lead applied scientist believes there's an opportunity to proactively address customer issues using machine learning. She requests access to all of the company's customer data and several publicly available datasets All the following are appropriate next steps EXCEPT?
正解：A
質問 # 167
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P.S. Tech4ExamがGoogle Driveで共有している無料かつ新しいCIPMダンプ：https://drive.google.com/open?id=13s1_OTRdSysZl8chavy3OPAzdjiT7Ss1