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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Operational Life Cycle of a Privacy Program | 50% | - Monitoring, auditing, and continuous improvement - Managing data inventory and data flows - Assessing privacy risks and impacts - Implementing privacy controls and procedures |
| Topic 2: Privacy Program Governance | 50% | - Metrics, reporting, and accountability - Privacy program structure and governance models - Policy development and implementation - Stakeholder engagement and communication |
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214. Frage
Which of the following information must be provided by the data controller when complying with GDPR "right to be informed" requirements?
Antwort: D
215. Frage
A start-up tech company is developing its privacy policies and processes.
Which policy is most important to ensure the organization is successful at processing consumer health information?
Antwort: A
Begründung:
Comprehensive and Detailed Explanation:
A consumer health data policy is the most critical document for ensuring that a start-up correctly processes consumer health information while maintaining compliance with relevant laws and privacy best practices.
Option A (Employee notice) focuses on employee privacy but does not directly regulate consumer health data.
Option C (Privacy Impact Assessment - PIA) is a risk assessment tool, not a policy that defines how consumer health data is processed.
Option D (HIPAA privacy notice) is only required for HIPAA-covered entities (such as healthcare providers, insurers, and clearinghouses), but many start-ups may not fall under HIPAA jurisdiction.
A consumer health data policy ensures that the company follows the correct data collection, storage, and processing requirements, regardless of whether HIPAA or another privacy law applies.
216. Frage
SCENARIO
Please use the following to answer the next QUESTION:
Edufox has hosted an annual convention of users of its famous e-learning software platform, and over time, it has become a grand event. It fills one of the large downtown conference hotels and overflows into the others, with several thousand attendees enjoying three days of presentations, panel discussions and networking. The convention is the centerpiece of the company's product rollout schedule and a great training opportunity for current users. The sales force also encourages prospective clients to attend to get a better sense of the ways in which the system can be customized to meet diverse needs and understand that when they buy into this system, they are joining a community that feels like family.
This year's conference is only three weeks away, and you have just heard news of a new initiative supporting it: a smartphone app for attendees. The app will support late registration, highlight the featured presentations and provide a mobile version of the conference program. It also links to a restaurant reservation system with the best cuisine in the areas featured. "It's going to be great," the developer, Deidre Hoffman, tells you, "if, that is, we actually get it working!" She laughs nervously but explains that because of the tight time frame she'd been given to build the app, she outsourced the job to a local firm. "It's just three young people," she says, "but they do great work." She describes some of the other apps they have built. When asked how they were selected for this job, Deidre shrugs. "They do good work, so I chose them." Deidre is a terrific employee with a strong track record. That's why she's been charged to deliver this rushed project. You're sure she has the best interests of the company at heart, and you don't doubt that she's under pressure to meet a deadline that cannot be pushed back. However, you have concerns about the app's handling of personal data and its security safeguards. Over lunch in the break room, you start to talk to her about it, but she quickly tries to reassure you, "I'm sure with your help we can fix any security issues if we have to, but I doubt there'll be any. These people build apps for a living, and they know what they're doing. You worry too much, but that's why you're so good at your job!" Since it is too late to restructure the contract with the vendor or prevent the app from being deployed, what is the best step for you to take next?
Antwort: D
Begründung:
This answer is the best step to take next, as it can help you to assess the current state of the vendor's privacy practices and determine if they meet the organization's standards and expectations, as well as the applicable laws and regulations. Asking the vendor for verifiable information about their privacy protections can include requesting documentation, evidence or demonstration of how they collect, use, store, protect, share and dispose of personal data, what policies and procedures they have in place, what technical and organizational measures they implement, what certifications or audits they have obtained or undergone, and how they handle any privacy incidents or breaches. Based on this information, you can identify any weaknesses or gaps in the vendor's privacy protections and recommend or require any improvements or corrections before the app is deployed. References: IAPP CIPM Study Guide, page 82; ISO/IEC 27002:2013, section 15.1.2
217. Frage
SCENARIO
Please use the following to answer the next question:
Liam is the newly appointed information technology (IT) compliance manager at Mesa, a USbased outdoor clothing brand with a global E-commerce presence. During his second week, he is contacted by the company' s IT audit manager, who informs him that the auditing team will be conducting a review of Mesa's privacy compliance risk in a month.
A bit nervous about the audit, Liam asks his boss what his predecessor had completed related to privacy compliance before leaving the company. Liam is told that a consent management tool had been added to the website and they commissioned a privacy risk evaluation from a small consulting firm last year that determined that their risk exposure was relatively low given their current control environment. After reading the consultant's report, Liam realized that the scope of the assessment was limited to breach notification laws in the US and the Payment Card Industry's Data Security Standard (PCI DSS).
Not wanting to let down his new team, Liam kept his concerns about the report to himself and figured he could try to put some additional controls into place before the audit. Having some privacy compliance experience in his last role, Liam thought he might start by having discussions with the E-commerce and marketing teams.
The E-commerce Director informed him that they were still using the cookie consent tool forcibly placed on the home screen by the CIO, but could not understand the point since their office was not located in California or Europe. The marketing director touted his department's success with purchasing email lists and taking a shotgun approach to direct marketing. Both directors highlighted their tracking tools on the website to enhance customer experience while learning more about where else the customer had shopped. The more people Liam met with, the more it became apparent that privacy awareness and the general control environment at Mesa needed help.
With three weeks before the audit, Liam updated Mesa's Privacy Notice himself, which was taken and revised from a competitor's website. He also wrote policies and procedures outlining the roles and responsibilities for privacy within Mesa and distributed the document to all departments he knew of with access to personal information.
During this time. Liam also filled the backlog of data subject requests for deletion that had been sent to him by the customer service manager. Liam worked with application owners to remove these individual's information and order history from the customer relationship management (CRM) tool, the enterprise resource planning (ERP). the data warehouse and the email server.
At the audit kick-off meeting. Liam explained to his boss and her team that there may still be some room for improvement, but he thought the risk had been mitigated to an appropriate level based on the work he had done thus far.
After the audit had been completed, the audit manager and Liam met to discuss her team's findings, and much to his dismay. Liam was told that none of the work he had completed prior to the audit followed best practices for governance and risk mitigation. In fact, his actions only opened the company up to additional risk and scrutiny. Based on these findings. Liam worked with external counsel and an established privacy consultant to develop a remediation plan.
What key error related to program governance did Liam make prior to the audit kick-off meeting?
Antwort: D
218. Frage
Which statement is FALSE regarding the use of technical security controls?
Antwort: C
Begründung:
Explanation
The statement that is false regarding the use of technical security controls is that most privacy legislation lists the types of technical security controls that must be implemented. Technical security controls are the hardware and software components that protect a system against cyberattacks, such as encryption, firewalls, antivirus software, and access control mechanisms1 However, most privacy legislation does not prescribe specific types of technical security controls that must be implemented by organizations. Instead, they usually require organizations to implement reasonable or appropriate technical security measures to protect personal data from unauthorized or unlawful access, use, disclosure, alteration, or destruction23 The exact level and type of technical security controls may depend on various factors, such as the nature and sensitivity of the data, the risks and threats involved, the state of the art technology available, and the cost and feasibility of implementation4 Therefore, organizations have some flexibility and discretion in choosing the most suitable technical security controls for their data processing activities. References: 1: Technical Controls - Cybersecurity Resilience - Resilient Energy Platform; 2: [General Data Protection Regulation (GDPR) - Official Legal Text], Article 32; 3: [Privacy Act 1988], Schedule 1 - Australian Privacy Principles (APPs), APP 11; 4: Technical Security Controls: Encryption, Firewalls & More
219. Frage
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