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| Section | Objectives |
|---|---|
| Sustaining Program Performance | - Implement continuous improvement - Monitor and audit privacy program - Measure program effectiveness |
| Establishing Governance | - Create privacy policies and procedures - Define roles and responsibilities - Establish reporting mechanisms |
| Protecting Personal Data | - Manage data subject rights - Implement privacy and security controls - Handle cross-border data transfers |
| Responding to Requests and Incidents | - Coordinate with regulators - Handle data subject requests - Manage data breaches and incidents |
| Developing a Framework | - Identify applicable laws and frameworks - Define program scope and stakeholders - Establish privacy governance structure |
| Assessing Data | - Conduct data inventory and mapping - Perform privacy impact assessments - Manage vendor and third-party risks |
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NEW QUESTION # 191
What is one obligation that the General Data Protection Regulation (GDPR) imposes on data processors?
Answer: D
Explanation:
Explanation
The GDPR imposes several obligations on data processors, such as maintaining records of processing activities, cooperating with supervisory authorities, and notifying data controllers of personal data breaches.
One of these obligations is to implement appropriate technical and organizational measures that ensure an appropriate level of security for the personal data processed on behalf of the data controller. This is stated in Article 28(1) and Article 32 of the GDPR1. The other options are not obligations of data processors under the GDPR, but rather of data controllers or joint responsibilities of both parties. References: GDPR
NEW QUESTION # 192
Which is TRUE about the scope and authority of data protection oversight authorities?
Answer: A
Explanation:
The true statement about the scope and authority of data protection oversight authorities is that no one agency officially oversees the enforcement of privacy regulations in the United States. Unlike other regions, such as the European Union or Canada, the United States does not have a comprehensive federal privacy law or a single national data protection authority. Instead, it has a patchwork of sector-specific and state-level laws and regulations, enforced by various federal and state agencies, such as the Federal Trade Commission (FTC), the Department of Health and Human Services (HHS), the Department of Commerce (DOC), etc. Additionally, individuals can also bring private lawsuits against organizations that violate their privacy rights. References:
[Data Protection Authorities], [Privacy Law in the United States]
NEW QUESTION # 193
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 # 194
What is the name for the privacy strategy model that describes delegated decision making?
Answer: C
Explanation:
Explanation
A matrix is a type of organizational structure that involves delegated decision making. In a matrix structure, employees report to more than one manager or leader, usually based on different functions or projects. For example, a software developer may report to both a product manager and a technical manager. A matrix structure allows for more flexibility, collaboration, and innovation in complex and dynamic environments.
The other options are not examples of delegated decision making structures. A de-centralized structure involves distributing decision making authority across different levels or units of the organization, rather than concentrating it at the top. A de-functionalized structure involves breaking down functional silos and creating cross-functional teams or processes. A hybrid structure involves combining elements of different types of structures, such as functional, divisional, or matrix.
NEW QUESTION # 195
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.
Which of the following was done CORRECTLY during the above incident?
Answer: D
Explanation:
Explanation
This answer is the only thing that was done correctly during the incident, as it shows a good practice of learning from and improving on the incident response process. The speed at which you sat down to reflect and document the incident means that you did not delay or postpone this important step, which can help you to capture and analyze what went well and what could have gone better during the incident, as well as to identify any lessons learned, best practices or recommendations for future incidents. Documenting and reflecting on the incident can also help you to update and improve your privacy policies, procedures and safeguards, as well as to demonstrate your accountability and compliance with any legal or contractual obligations.
NEW QUESTION # 196
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