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| Section | Objectives |
|---|---|
| Topic 1: Protecting Personal Data | - Handle cross-border data transfers - Implement privacy and security controls - Manage data subject rights |
| Topic 2: Assessing Data | - Manage vendor and third-party risks - Perform privacy impact assessments - Conduct data inventory and mapping |
| Topic 3: Establishing Governance | - Create privacy policies and procedures - Define roles and responsibilities - Establish reporting mechanisms |
| Topic 4: Developing a Framework | - Identify applicable laws and frameworks - Establish privacy governance structure - Define program scope and stakeholders |
| Topic 5: Responding to Requests and Incidents | - Manage data breaches and incidents - Handle data subject requests - Coordinate with regulators |
| Topic 6: Sustaining Program Performance | - Measure program effectiveness - Implement continuous improvement - Monitor and audit privacy program |
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NEW QUESTION # 120
All of the following would address your concern of the copy room EXCEPT?
Answer: D
Explanation:
Step-by-Step Comprehensive Detailed Explanation with All Information Privacy Manager CIPM Study Guide References When addressing concerns related to the copy room and managing paper-based records, the goal is to implement practical solutions for safeguarding privacy and ensuring proper data handling. Let's evaluate the options:
A). Placing a paper shredder in the copy room:
This is a direct and practical measure to address the concern by providing users with the means to destroy sensitive documents immediately.
B). Initiating a PIA (Privacy Impact Assessment):
A Privacy Impact Assessment is a systematic process to evaluate the privacy risks of a new system or process.
While valuable in many scenarios, a PIA does not directly address the immediate concern about safeguarding paper records in the copy room.
C). Hanging a poster reminding users to shred paper:
This raises awareness and encourages compliance with secure document destruction practices, directly addressing the concern.
D). Implementing a new paper record destruction policy:
A new policy establishes clear guidelines for the destruction of sensitive paper records, ensuring consistent and compliant practices.
CIPM Study Guide References:
* Privacy Program Operational Life Cycle - "Protect" phase emphasizes securing physical records.
* Awareness and training programs highlight posters as tools for educating users.
* Policies and procedures for data disposal are discussed under record management and retention.
NEW QUESTION # 121
SCENARIO
Please use the following to answer the next QUESTION:
It's just what you were afraid of. Without consulting you, the information technology director at your organization launched a new initiative to encourage employees to use personal devices for conducting business. The initiative made purchasing a new, high-specification laptop computer an attractive option, with discounted laptops paid for as a payroll deduction spread over a year of paychecks. The organization is also paying the sales taxes. It's a great deal, and after a month, more than half the organization's employees have signed on and acquired new laptops. Walking through the facility, you see them happily customizing and comparing notes on their new computers, and at the end of the day, most take their laptops with them, potentially carrying personal data to their homes or other unknown locations. It's enough to give you data- protection nightmares, and you've pointed out to the information technology Director and many others in the organization the potential hazards of this new practice, including the inevitability of eventual data loss or theft.
Today you have in your office a representative of the organization's marketing department who shares with you, reluctantly, a story with potentially serious consequences. The night before, straight from work, with laptop in hand, he went to the Bull and Horn Pub to play billiards with his friends. A fine night of sport and socializing began, with the laptop "safely" tucked on a bench, beneath his jacket. Later that night, when it was time to depart, he retrieved the jacket, but the laptop was gone. It was not beneath the bench or on another bench nearby. The waitstaff had not seen it. His friends were not playing a joke on him. After a sleepless night, he confirmed it this morning, stopping by the pub to talk to the cleanup crew. They had not found it. The laptop was missing. Stolen, it seems. He looks at you, embarrassed and upset.
You ask him if the laptop contains any personal data from clients, and, sadly, he nods his head, yes. He believes it contains files on about 100 clients, including names, addresses and governmental identification numbers. He sighs and places his head in his hands in despair.
From a business standpoint, what is the most productive way to view employee use of personal equipment for work-related tasks?
Answer: B
NEW QUESTION # 122
SCENARIO
Please use the following to answer the next QUESTION:
Martin Briseño is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseño decided to change the hotel's on-the-job mentoring model to a standardized training program for employees who were progressing from line positions into supervisory positions. He developed a curriculum comprising a series of lessons, scenarios, and assessments, which was delivered in-person to small groups. Interest in the training increased, leading Briseño to work with corporate HR specialists and software engineers to offer the program in an online format. The online program saved the cost of a trainer and allowed participants to work through the material at their own pace.
Upon hearing about the success of Briseño's program, Pacific Suites corporate Vice President Maryanne Silva-Hayes expanded the training and offered it company-wide. Employees who completed the program received certification as a Pacific Suites Hospitality Supervisor. By 2001, the program had grown to provide industry-wide training. Personnel at hotels across the country could sign up and pay to take the course online.
As the program became increasingly profitable, Pacific Suites developed an offshoot business, Pacific Hospitality Training (PHT). The sole focus of PHT was developing and marketing a variety of online courses and course progressions providing a number of professional certifications in the hospitality industry.
By setting up a user account with PHT, course participants could access an information library, sign up for courses, and take end-of-course certification tests. When a user opened a new account, all information was saved by default, including the user's name, date of birth, contact information, credit card information, employer, and job title. The registration page offered an opt-out choice that users could click to not have their credit card numbers saved. Once a user name and password were established, users could return to check their course status, review and reprint their certifications, and sign up and pay for new courses. Between 2002 and
2008, PHT issued more than 700,000 professional certifications.
PHT's profits declined in 2009 and 2010, the victim of industry downsizing and increased competition from e- learning providers. By 2011, Pacific Suites was out of the online certification business and PHT was dissolved. The training program's systems and records remained in Pacific Suites' digital archives, un- accessed and unused. Briseño and Silva-Hayes moved on to work for other companies, and there was no plan for handling the archived data after the program ended. After PHT was dissolved, Pacific Suites executives turned their attention to crucial day-to-day operations. They planned to deal with the PHT materials once resources allowed.
In 2012, the Pacific Suites computer network was hacked. Malware installed on the online reservation system exposed the credit card information of hundreds of hotel guests. While targeting the financial data on the reservation site, hackers also discovered the archived training course data and registration accounts of Pacific Hospitality Training's customers. The result of the hack was the exfiltration of the credit card numbers of recent hotel guests and the exfiltration of the PHT database with all its contents.
A Pacific Suites systems analyst discovered the information security breach in a routine scan of activity reports. Pacific Suites quickly notified credit card companies and recent hotel guests of the breach, attempting to prevent serious harm. Technical security engineers faced a challenge in dealing with the PHT data.
PHT course administrators and the IT engineers did not have a system for tracking, cataloguing, and storing information. Pacific Suites has procedures in place for data access and storage, but those procedures were not implemented when PHT was formed. When the PHT database was acquired by Pacific Suites, it had no owner or oversight. By the time technical security engineers determined what private information was compromised, at least 8,000 credit card holders were potential victims of fraudulent activity.
In the Information Technology engineers had originally set the default for customer credit card information to
"Do Not Save," this action would have been in line with what concept?
Answer: C
NEW QUESTION # 123
What should be the first major goal of a company developing a new privacy program?
Answer: C
Explanation:
The first major goal of a company developing a new privacy program should be to schedule conversations with executives of affected departments. This is because a privacy program requires the support and involvement of senior management and key stakeholders from different business units, such as legal, IT, marketing, human resources, etc. By engaging with them early on, a privacy professional can understand their needs, expectations, challenges, and risks, and align the privacy program objectives and strategies with the organization's goals and culture. Reference: [How to Develop a Privacy Program], [Privacy Program Management]
NEW QUESTION # 124
Which of the following is NOT a main technical data control area?
Answer: A
Explanation:
Explanation
Obfuscation is not a main technical data control area. Obfuscation means hiding or disguising data or information to make it less intelligible or accessible. Obfuscation can be used as a security measure or a privacy-enhancing technique, but it is not a specific type of data control. The main technical data control areas are tokenization, encryption, access controls, and data minimization. Tokenization means replacing sensitive data with non-sensitive substitutes called tokens that have no intrinsic value. Encryption means transforming data into an unreadable format that can only be decrypted with a key. Access controls mean restricting who can access or modify data based on their roles, permissions, or authentication methods. Data minimization means collecting, storing, and processing only the minimum amount of data necessary for a specific purpose1, 2. References: CIPM - International Association of Privacy Professionals, Free CIPM Study Guide - International Association of Privacy Professionals
NEW QUESTION # 125
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