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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Establishing Program Governance | 17–22% | - Stakeholder engagement and communication - Policies, procedures and standards - Training and awareness programs - Accountability and oversight mechanisms |
| Topic 2: Assessing Data and Privacy Risks | 17–22% | - Data inventory and mapping - Compliance gap analysis - Risk identification, analysis and mitigation - Privacy impact assessments (PIA/DPIA) |
| Topic 3: Protecting Personal Data | 12–18% | - Cross-border data transfers - Technical and organizational safeguards - Data lifecycle management - Privacy by design and default |
| Topic 4: Sustaining Program Performance | 10–15% | - Continuous improvement - Monitoring, auditing and reporting - Change management - Performance metrics and KPIs |
| Topic 5: Developing a Privacy Program Framework | 15–20% | - Legal and regulatory requirements - Privacy vision, strategy and objectives - Program governance structure and roles - Program scope and boundaries |
| Topic 6: Responding to Requests and Incidents | 14–18% | - Data subject rights management - Breach detection, notification and remediation - Regulatory interaction and reporting - Privacy incident response plan |
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108. Frage
What should a privacy professional keep in mind when selecting which metrics to collect?
Antwort: C
Begründung:
Explanation
A privacy professional should keep in mind that the number of metrics should be limited at first when selecting which metrics to collect. Metrics are quantitative measures that help evaluate the performance and effectiveness of a privacy program. However, collecting too many metrics can be overwhelming, confusing, and costly. Therefore, a privacy professional should start with a few key metrics that are relevant, meaningful, actionable, and aligned with the organization's privacy goals and priorities. These metrics can be refined and expanded over time as the privacy program matures and evolves. References: [Privacy Metrics], [Measuring Privacy Program Effectiveness]
109. Frage
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?
Antwort: C
Begründung:
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
110. Frage
SCENARIO
Please use the following to answer the next QUESTION:
You lead the privacy office for a company that handles information from individuals living in several countries throughout Europe and the Americas. You begin that morning's privacy review when a contracts officer sends you a message asking for a phone call. The message lacks clarity and detail, but you presume that data was lost.
When you contact the contracts officer, he tells you that he received a letter in the mail from a vendor stating that the vendor improperly shared information about your customers. He called the vendor and confirmed that your company recently surveyed exactly 2000 individuals about their most recent healthcare experience and sent those surveys to the vendor to transcribe it into a database, but the vendor forgot to encrypt the database as promised in the contract. As a result, the vendor has lost control of the data.
The vendor is extremely apologetic and offers to take responsibility for sending out the notifications. They tell you they set aside 2000 stamped postcards because that should reduce the time it takes to get the notice in the mail. One side is limited to their logo, but the other side is blank and they will accept whatever you want to write. You put their offer on hold and begin to develop the text around the space constraints. You are content to let the vendor's logo be associated with the notification.
The notification explains that your company recently hired a vendor to store information about their most recent experience at St. Sebastian Hospital's Clinic for Infectious Diseases. The vendor did not encrypt the information and no longer has control of it. All 2000 affected individuals are invited to sign-up for email notifications about their information. They simply need to go to your company's website and watch a quick advertisement, then provide their name, email address, and month and year of birth.
You email the incident-response council for their buy-in before 9 a.m. If anything goes wrong in this situation, you want to diffuse the blame across your colleagues. Over the next eight hours, everyone emails their comments back and forth. The consultant who leads the incident-response team notes that it is his first day with the company, but he has been in other industries for 45 years and will do his best. One of the three lawyers on the council causes the conversation to veer off course, but it eventually gets back on track. At the end of the day, they vote to proceed with the notification you wrote and use the vendor's postcards.
Shortly after the vendor mails the postcards, you learn the data was on a server that was stolen, and make the decision to have your company offer credit monitoring services. A quick internet search finds a credit monitoring company with a convincing name: Credit Under Lock and Key (CRUDLOK). Your sales rep has never handled a contract for 2000 people, but develops a proposal in about a day which says CRUDLOK will:
1. Send an enrollment invitation to everyone the day after the contract is signed.
2. Enroll someone with just their first name and the last-4 of their national identifier.
3. Monitor each enrollee's credit for two years from the date of enrollment.
4. Send a monthly email with their credit rating and offers for credit-related services at market rates.
5. Charge your company 20% of the cost of any credit restoration.
You execute the contract and the enrollment invitations are emailed to the 2000 individuals. Three days later you sit down and document all that went well and all that could have gone better. You put it in a file to reference the next time an incident occurs.
Regarding the notification, which of the following would be the greatest concern?
Antwort: D
Begründung:
This answer is the greatest concern regarding the notification, as it violates the data minimization principle and exposes the affected individuals to further privacy and security risks. Collecting more personally identifiable information than necessary to provide updates to the affected individuals means that the company is asking for their name, email address, and month and year of birth, which may not be relevant or proportionate for the purpose of sending email notifications. Collecting more information than necessary can also increase the likelihood of data breaches, identity theft, fraud, or misuse of the data by unauthorized or malicious parties.
111. Frage
SCENARIO
Please use the following to answer the next QUESTION:
As they company's new chief executive officer, Thomas Goddard wants to be known as a leader in data protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically Questionable practices, including unauthorized sales of personal data to marketers.
Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company's claims that
"appropriate" data protection safeguards were in place. The scandal affected the company's business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard's mentor, was forced to step down.
Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company's board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures.
He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. "We want Medialite to have absolutely the highest standards," he says. "In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company's finances. So, while I want the best solutions across the board, they also need to be cost effective." You are told to report back in a week's time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.
You give a presentation to your CEO about privacy program maturity. What does it mean to have a "managed" privacy program, according to the AICPA/CICA Privacy Maturity Model?
Antwort: D
Begründung:
Explanation
This answer is the best way to describe what it means to have a "managed" privacy program, according to the AICPA/CICA Privacy Maturity Model (PMM), which is a framework that measures the effectiveness and maturity of an organization's privacy program based on five phases: ad hoc, repeatable, defined, managed and optimized. The managed phase is the fourth level of maturity in the PMM, which indicates that the organization has a formal and consistent approach to privacy protection and that its privacy practices are aligned with its policies and objectives. The managed phase means that the organization has procedures and processes that are fully documented and implemented, and cover all relevant aspects of data collection, use, storage, protection, sharing and disposal. The managed phase also means that the organization has controls and measures that are monitored and evaluated regularly, and that any issues or incidents are reported and resolved promptly.
112. Frage
An organization's privacy officer was just notified by the benefits manager that she accidentally sent out the retirement enrollment report of all employees to a wrong vendor.
Which of the following actions should the privacy officer take first?
Antwort: A
Begründung:
The first action that the privacy officer should take after being notified by the benefits manager that she accidentally sent out the retirement enrollment report of all employees to a wrong vendor is to perform a risk of harm analysis. A risk of harm analysis is a process of assessing the potential adverse consequences for the individuals whose personal data has been compromised by a data breach or incident5 The purpose of this analysis is to determine whether the breach or incident poses a significant risk of harm to the affected individuals, such as identity theft, fraud, discrimination, physical harm, emotional distress, or reputational damage6 The risk of harm analysis should consider various factors, such as the type and amount of data involved, the sensitivity and context of the data, the likelihood and severity of harm, the characteristics of the recipients or unauthorized parties who accessed the data, and the mitigating measures taken or available to reduce the harm7 Based on this analysis, the privacy officer can then decide whether to notify the affected individuals, the relevant authorities, or other stakeholders about the breach or incident. Notification is usually required by law or best practice when there is a high risk of harm to the individuals as a result of the breach or incident8 Notification can also help to mitigate the harm by allowing the individuals to take protective actions or seek remedies. Therefore, performing a risk of harm analysis is a crucial first step for responding to a data breach or incident. Reference: 5: Can a risk of harm itself be a harm? | Analysis | Oxford Academic; 6: No Harm Done? Assessing Risk of Harm under the Federal Breach Notification Rule; 7: CCOHS: Hazard and Risk - Risk Assessment; 8: Breach Notification Requirements in Canada | PrivacySense.net
113. Frage
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