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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Operational Life Cycle of a Privacy Program | 50% | - Assessing privacy risks and impacts - Monitoring, auditing, and continuous improvement - Implementing privacy controls and procedures - Managing data inventory and data flows |
| Topic 2: Privacy Program Governance | 50% | - Privacy program structure and governance models - Policy development and implementation - Stakeholder engagement and communication - Metrics, reporting, and accountability |
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NEW QUESTION # 113
Which item below best represents how a privacy group can effectively communicate with functional areas?
Answer: D
NEW QUESTION # 114
How do privacy audits differ from privacy assessments?
Answer: B
NEW QUESTION # 115
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 does this example best illustrate about training requirements for privacy protection?
Answer: C
Explanation:
Explanation
This answer is the best way to illustrate the training requirements for privacy protection, as it shows the importance of understanding and complying with the different legal and regulatory frameworks that apply to the organization's data processing activities in different jurisdictions. Training on local laws must be implemented for all personnel who are involved in or responsible for collecting, using, disclosing, storing or transferring personal data across borders, as they may face different obligations and restrictions depending on the nature and location of the data and the data subjects. Training on local laws can help to prevent or mitigate the risks of violating the privacy rights of individuals, facing legal actions, fines, sanctions or investigations from authorities, or losing trust and reputation among customers, partners and stakeholders. References: IAPP CIPM Study Guide, page 901; ISO/IEC 27002:2013, section 7.2.2
NEW QUESTION # 116
SCENARIO
Please use the following to answer the next QUESTION:
Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner, Anton, has found some degree of disorganization after touring the company headquarters. His uncle Henry had always focused on production - not data processing - and Anton is concerned. In several storage rooms, he has found paper files, disks, and old computers that appear to contain the personal data of current and former employees and customers. Anton knows that a single break-in could irrevocably damage the company's relationship with its loyal customers. He intends to set a goal of guaranteed zero loss of personal information.
To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of the company. However, Kenneth - his uncle's vice president and longtime confidante - wants to hold off on Anton's idea in favor of converting any paper records held at the company to electronic storage. Kenneth believes this process would only take one or two years. Anton likes this idea; he envisions a password- protected system that only he and Kenneth can access.
Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier, but it will simplify the management of the stored data. The heads of subsidiaries like the art gallery and kitchenware store down the street will be responsible for their own information management. Then, any unneeded subsidiary data still in Anton's possession can be destroyed within the next few years.
After learning of a recent security incident, Anton realizes that another crucial step will be notifying customers. Kenneth insists that two lost hard drives in Question are not cause for concern; all of the data was encrypted and not sensitive in nature. Anton does not want to take any chances, however. He intends on sending notice letters to all employees and customers to be safe.
Anton must also check for compliance with all legislative, regulatory, and market requirements related to privacy protection. Kenneth oversaw the development of the company's online presence about ten years ago, but Anton is not confident about his understanding of recent online marketing laws. Anton is assigning another trusted employee with a law background the task of the compliance assessment. After a thorough analysis, Anton knows the company should be safe for another five years, at which time he can order another check.
Documentation of this analysis will show auditors due diligence.
Anton has started down a long road toward improved management of the company, but he knows the effort is worth it. Anton wants his uncle's legacy to continue for many years to come.
What would the company's legal team most likely recommend to Anton regarding his planned communication with customers?
Answer: D
Explanation:
The company's legal team would most likely recommend Anton to consider under what circumstances communication with customers is necessary after learning of a recent security incident. Communication with customers is an important aspect of data breach response as it can help to mitigate the harm caused by the breach, restore trust and confidence in the company, and comply with legal obligations or best practices. However, communication with customers is not always mandatory or advisable depending on the nature and severity of the breach and the potential impact on the customers7 Therefore, Anton should consult with his legal team and evaluate the following factors before deciding whether to communicate with customers or not:
* The type and amount of data involved in the breach and whether it includes personal or sensitive information that could expose the customers to identity theft, fraud, or other harms.
* The likelihood and extent of harm that the customers could suffer as a result of the breach and whether they could take any actions to prevent or reduce it.
* The legal or contractual obligations that the company has to notify the customers or the relevant authorities about the breach and the applicable laws or regulations that govern the notification process, such as the timing, content, and method of notification.
* The potential benefits and risks of communicating with customers, such as enhancing transparency and accountability, providing assistance and remedies, or triggering negative reactions, reputational damage, or legal claims.
Based on these factors, Anton should determine whether communication with customers is necessary and appropriate in his case. If he decides to communicate with customers, he should follow some best practices, such as:
* Communicating as soon as possible after discovering and containing the breach and having sufficient information to share.
* Communicating clearly, honestly, and empathetically about what happened, what data was affected, what actions the company has taken or will take, and what steps the customers can or should take.
* Communicating through multiple channels, such as email, phone, letter, website, or social media, depending on the preferences and expectations of the customers.
* Communicating consistently and regularly with updates or follow-ups until the breach is resolved and the customers are satisfied8: 7: How to Communicate a Data Breach to Customers - U.S. Chamber of Commerce; 8: The do's and don'ts of communicating a data breach
NEW QUESTION # 117
Your marketing team wants to know why they need a check box for their SMS opt-in. You explain it is part of the consumer's right to?
Answer: A
Explanation:
The marketing team needs a check box for their SMS opt-in because it is part of the consumer's right to be informed. This right means that consumers have the right to know how their personal data is collected, used, shared, and protected by the organization. The check box allows consumers to give their consent and opt-in to receive SMS messages from the organization, and also informs them of the purpose and scope of such messages. The other rights are not relevant in this case, as they are related to other aspects of data processing, such as correction, complaints, and access. References: CIPM Body of Knowledge, Domain IV: Privacy Program Communication, Section A: Communicating to Stakeholders, Subsection 1: Consumer Rights.
NEW QUESTION # 118
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