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| Section | Objectives |
|---|---|
| Topic 1: Sustaining Program Performance | - Measure program effectiveness - Implement continuous improvement - Monitor and audit privacy program |
| Topic 2: Protecting Personal Data | - Implement privacy and security controls - Manage data subject rights - Handle cross-border data transfers |
| Topic 3: Establishing Governance | - Establish reporting mechanisms - Define roles and responsibilities - Create privacy policies and procedures |
| Topic 4: Developing a Framework | - Establish privacy governance structure - Define program scope and stakeholders - Identify applicable laws and frameworks |
| Topic 5: Responding to Requests and Incidents | - Handle data subject requests - Manage data breaches and incidents - Coordinate with regulators |
| Topic 6: Assessing Data | - Manage vendor and third-party risks - Perform privacy impact assessments - Conduct data inventory and mapping |
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NEW QUESTION # 216
When building a data privacy program, what is a good starting point to understand the scope of privacy program needs?
Answer: A
Explanation:
A data inventory is a good starting point to understand the scope of privacy program needs, as it provides a comprehensive overview of what personal data is collected, processed, stored, shared, and disposed of by the organization. A data inventory can help identify the legal obligations, risks, and gaps in the privacy program, as well as the opportunities for improvement and optimization. The other options are also important components of a privacy program, but they are more effective when based on a data inventory. References: CIPM Body of Knowledge, Domain II: Privacy Program Operational Life Cycle, Task
1: Assess the current state of the privacy program.
NEW QUESTION # 217
Which term describes a piece of personal data that alone may not identify an individual?
Answer: D
Explanation:
A single attribute is a term that describes a piece of personal data that alone may not identify an individual, such as a first name or a zip code. However, when combined with other attributes, it may become identifiable. References: IAPP CIPM Study Guide, page 18.
NEW QUESTION # 218
SCENARIO
Please use the following to answer the next QUESTION:
For 15 years, Albert has worked at Treasure Box - a mail order company in the United States (U.S.) that used to sell decorative candles around the world, but has recently decided to limit its shipments to customers in the
48 contiguous states. Despite his years of experience, Albert is often overlooked for managerial positions. His frustration about not being promoted, coupled with his recent interest in issues of privacy protection, have motivated Albert to be an agent of positive change.
He will soon interview for a newly advertised position, and during the interview, Albert plans on making executives aware of lapses in the company's privacy program. He feels certain he will be rewarded with a promotion for preventing negative consequences resulting from the company's outdated policies and procedures.
For example, Albert has learned about the AICPA (American Institute of Certified Public Accountans)/CICA (Canadian Institute of Chartered Accountants) Privacy Maturity Model (PMM). Albert thinks the model is a useful way to measure Treasure Box's ability to protect personal data. Albert has noticed that Treasure Box fails to meet the requirements of the highest level of maturity of this model; at his interview, Albert will pledge to assist the company with meeting this level in order to provide customers with the most rigorous security available.
Albert does want to show a positive outlook during his interview. He intends to praise the company's commitment to the security of customer and employee personal data against external threats. However, Albert worries about the high turnover rate within the company, particularly in the area of direct phone marketing. He sees many unfamiliar faces every day who are hired to do the marketing, and he often hears complaints in the lunch room regarding long hours and low pay, as well as what seems to be flagrant disregard for company procedures.
In addition, Treasure Box has had two recent security incidents. The company has responded to the incidents with internal audits and updates to security safeguards. However, profits still seem to be affected and anecdotal evidence indicates that many people still harbor mistrust. Albert wants to help the company recover.
He knows there is at least one incident the public in unaware of, although Albert does not know the details. He believes the company's insistence on keeping the incident a secret could be a further detriment to its reputation. One further way that Albert wants to help Treasure Box regain its stature is by creating a toll-free number for customers, as well as a more efficient procedure for responding to customer concerns by postal mail.
In addition to his suggestions for improvement, Albert believes that his knowledge of the company's recent business maneuvers will also impress the interviewers. For example, Albert is aware of the company's intention to acquire a medical supply company in the coming weeks.
With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the job.
Based on Albert's observations regarding recent security incidents, which of the following should he suggest as a priority for Treasure Box?
Answer: B
Explanation:
Explanation
This answer is the best suggestion that Albert should make based on his observations regarding recent security incidents, as it can help to ensure that Treasure Box's privacy program and practices are assessed and verified by an independent and objective party who has the necessary expertise, experience and credentials to evaluate the company's compliance with the applicable laws, regulations, standards and best practices for data protection. Using a third-party auditor can also help to identify any gaps, weaknesses or risks that may have been overlooked or missed by the prior internal audits, and to recommend or implement any improvements or corrective actions. A third-party audit can also help to enhance the company's reputation and trust among its customers, partners and stakeholders, as well as demonstrate its commitment and accountability for privacy protection.
NEW QUESTION # 219
Under the General Data Protection Regulation (GDPR), what are the obligations of a processor that engages a sub-processor?
Answer: C
Explanation:
Under the General Data Protection Regulation (GDPR), the obligations of a processor that engages a sub-processor are to obtain the consent of the controller and ensure the sub-processor complies with data processing obligations that are equivalent to those that apply to the processor. The GDPR defines a processor as a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller. A sub-processor is a third party that is engaged by the processor to carry out specific processing activities on behalf of the controller. The GDPR requires that the processor does not engage another processor without prior specific or general written authorization of the controller. In the case of general written authorization, the processor must inform the controller of any intended changes concerning the addition or replacement of other processors, thereby giving the controller the opportunity to object to such changes. The processor must also ensure that the same data protection obligations as set out in the contract or other legal act between the controller and the processor are imposed on that other processor by way of a contract or other legal act under Union or Member State law, . Reference: [GDPR Article 28], [CIPM - International Association of Privacy Professionals]
NEW QUESTION # 220
What are you doing if you succumb to "overgeneralization" when analyzing data from metrics?
Answer: B
Explanation:
If you succumb to "overgeneralization" when analyzing data from metrics, you are using data that is too broad to capture specific meanings. For example, if you use a single metric such as "number of complaints" to measure customer satisfaction, you are ignoring other factors that may affect customer satisfaction such as quality of service, responsiveness, or loyalty. You are also assuming that all complaints are equally valid and important, which may not be the case. To avoid overgeneralization, you should use multiple metrics that are relevant, specific, and measurable for your objectives. References: [IAPP CIPM Study Guide], page 59-60;
[Avoiding Overgeneralization in Data Analysis]
NEW QUESTION # 221
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