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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Developing a Privacy Program Framework | 15–20% | - Program governance structure and roles - Program scope and boundaries - Privacy vision, strategy and objectives - Legal and regulatory requirements |
| Topic 2: Establishing Program Governance | 17–22% | - Accountability and oversight mechanisms - Training and awareness programs - Stakeholder engagement and communication - Policies, procedures and standards |
| Topic 3: Responding to Requests and Incidents | 14–18% | - Regulatory interaction and reporting - Data subject rights management - Breach detection, notification and remediation - Privacy incident response plan |
| Topic 4: Assessing Data and Privacy Risks | 17–22% | - Privacy impact assessments (PIA/DPIA) - Risk identification, analysis and mitigation - Data inventory and mapping - Compliance gap analysis |
| Topic 5: Protecting Personal Data | 12–18% | - Data lifecycle management - Privacy by design and default - Technical and organizational safeguards - Cross-border data transfers |
| Topic 6: Sustaining Program Performance | 10–15% | - Performance metrics and KPIs - Continuous improvement - Monitoring, auditing and reporting - Change management |
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NEW QUESTION # 245
An organization's business continuity plan or disaster recovery plan does NOT typically include what?
Answer: B
Explanation:
An organization's business continuity plan or disaster recovery plan does not typically include a retention schedule for storage and destruction of information. A retention schedule is a document that specifies how long different types of information should be kept by an organization before they are disposed of or destroyed. A retention schedule is usually based on legal, regulatory, operational, historical, or archival requirements. A retention schedule is part of an organization's information governance or records management policy, not its business continuity or disaster recovery plan.
A business continuity plan (BCP) is a document that outlines how an organization will continue its critical functions and operations in the event of a disruption or disaster. A BCP usually includes:
Contact information and service level agreements (SLAs) for key personnel, stakeholders, providers, backup site operators, etc.
Business impact analysis (BIA) that identifies the potential impacts of disruption on all aspects of the business, such as financial, legal, reputational, etc.
Risk assessment that identifies and evaluates the likelihood and severity of various threats and vulnerabilities that could cause disruption or disaster.
Identification of critical functions that are essential for the survival and recovery of the business.
Communications plan that specifies how to communicate with internal and external parties during and after a disruption or disaster.
Testing plan that specifies how to test and update the BCP regularly to ensure its effectiveness and validity.
A disaster recovery plan (DRP) is a document that outlines how an organization will restore its IT systems, data, applications, and infrastructure in the event of a disruption or disaster. A DRP usually includes:
Recovery time objectives (RTOs) that specify how quickly each IT system or service needs to be restored after a disruption or disaster.
Recovery point objectives (RPOs) that specify how much data loss is acceptable for each IT system or service after a disruption or disaster.
Emergency response guidelines that specify how to respond to and contain a disruption or disaster, such as activating the DRP, declaring a disaster, notifying the stakeholders, etc.
Statement of organizational responsibilities that specifies who is responsible for what tasks and roles during and after a disruption or disaster, such as initiating the DRP, executing the recovery procedures, restoring the IT systems or services, etc.
Recovery procedures that specify how to recover each IT system or service from backup sources, such as backup tapes, disks, cloud services, etc.
Testing plan that specifies how to test and update the DRP regularly to ensure its effectiveness and validity. Reference: [Business Continuity Plan (BCP) Definition]; [Disaster Recovery Plan (DRP) Definition]
NEW QUESTION # 246
Which of the following is a physical control that can limit privacy risk?
Answer: B
Explanation:
Explanation
A physical control that can limit privacy risk is keypad or biometric access. This is a type of access control that restricts who can enter or access a physical location or device where personal data is stored or processed.
Keypad or biometric access requires a code or a biological feature (such as a fingerprint or a face scan) to authenticate the identity and authorization of the person seeking access. This can prevent unauthorized access, theft, loss, or damage of personal data by outsiders or insiders, . References: [CIPM - International Association of Privacy Professionals], [Free CIPM Study Guide - International Association of Privacy Professionals]
NEW QUESTION # 247
SCENARIO
Please use the following to answer the next QUESTION:
Ben works in the IT department of IgNight, Inc., a company that designs lighting solutions for its clients.
Although IgNight's customer base consists primarily of offices in the US, some individuals have been so impressed by the unique aesthetic and energy-saving design of the light fixtures that they have requested IgNight's installations in their homes across the globe.
One Sunday morning, while using his work laptop to purchase tickets for an upcoming music festival, Ben happens to notice some unusual user activity on company files. From a cursory review, all the data still appears to be where it is meant to be but he can't shake off the feeling that something is not right. He knows that it is a possibility that this could be a colleague performing unscheduled maintenance, but he recalls an email from his company's security team reminding employees to be on alert for attacks from a known group of malicious actors specifically targeting the industry.
Ben is a diligent employee and wants to make sure that he protects the company but he does not want to bother his hard-working colleagues on the weekend. He is going to discuss the matter with this manager first thing in the morning but wants to be prepared so he can demonstrate his knowledge in this area and plead his case for a promotion.
Going forward, what is the best way for IgNight to prepare its IT team to manage these kind of security events?
Answer: B
Explanation:
The best way for IgNight to prepare its IT team to manage these kind of security events is to conduct tabletop exercises. Tabletop exercises are simulated scenarios that test the organization's ability to respond to security incidents in a realistic and interactive way. Tabletop exercises typically involve:
* A facilitator who guides the participants through the scenario and injects additional challenges or variables
* A scenario that describes a plausible security incident based on real-world threats or past incidents
* A set of objectives that define the expected outcomes and goals of the exercise
* A set of questions that prompt the participants to discuss their roles, responsibilities, actions, decisions, and communications during the incident response process
* A feedback mechanism that collects the participants' opinions and suggestions on how to improve the incident response plan and capabilities Tabletop exercises help an organization prepare for and deal with security incidents by:
* Enhancing the awareness and skills of the IT team and other stakeholders involved in incident response
* Identifying and addressing the gaps, weaknesses, and challenges in the incident response plan and process
* Improving the coordination and collaboration among the IT team and other stakeholders during incident response
* Evaluating and validating the effectiveness and efficiency of the incident response plan and process
* Generating and implementing lessons learned and best practices for incident response The other options are not as effective or useful as tabletop exercises for preparing the IT team to manage security events. Updating the data inventory is a good practice for maintaining an accurate and comprehensive record of the personal data that the organization collects, processes, stores, shares, or disposes of. However, it does not test or improve the organization's incident response capabilities or readiness. IT security awareness training is a good practice for educating the IT team and other employees on the basic principles and practices of cybersecurity. However, it does not simulate or replicate the real-world situations and challenges that the IT team may face during security incidents. Sharing communications relating to scheduled maintenance is a good practice for informing the IT team and other stakeholders of the planned activities and potential impacts on the IT systems and infrastructure. However, it does not prepare the IT team for dealing with unplanned or unexpected security events that may require immediate and coordinated response. References: CISA Tabletop Exercise Packages; Cybersecurity Tabletop Exercise Examples, Best Practices, and Considerations; Six Tabletop Exercises to Help Prepare Your Cybersecurity Team
NEW QUESTION # 248
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?
Answer: C
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
NEW QUESTION # 249
SCENARIO
Please use the following to answer the next QUESTION:
Natalia, CFO of the Nationwide Grill restaurant chain, had never seen her fellow executives so anxious. Last week, a data processing firm used by the company reported that its system may have been hacked, and customer data such as names, addresses, and birthdays may have been compromised. Although the attempt was proven unsuccessful, the scare has prompted several Nationwide Grill executives to Question the company's privacy program at today's meeting.
Alice, a vice president, said that the incident could have opened the door to lawsuits, potentially damaging Nationwide Grill's market position. The Chief Information Officer (CIO), Brendan, tried to assure her that even if there had been an actual breach, the chances of a successful suit against the company were slim. But Alice remained unconvinced.
Spencer - a former CEO and currently a senior advisor - said that he had always warned against the use of contractors for data processing. At the very least, he argued, they should be held contractually liable for telling customers about any security incidents. In his view, Nationwide Grill should not be forced to soil the company name for a problem it did not cause.
One of the business development (BD) executives, Haley, then spoke, imploring everyone to see reason.
"Breaches can happen, despite organizations' best efforts," she remarked. "Reasonable preparedness is key." She reminded everyone of the incident seven years ago when the large grocery chain Tinkerton's had its financial information compromised after a large order of Nationwide Grill frozen dinners. As a long-time BD executive with a solid understanding of Tinkerton's's corporate culture, built up through many years of cultivating relationships, Haley was able to successfully manage the company's incident response.
Spencer replied that acting with reason means allowing security to be handled by the security functions within the company - not BD staff. In a similar way, he said, Human Resources (HR) needs to do a better job training employees to prevent incidents. He pointed out that Nationwide Grill employees are overwhelmed with posters, emails, and memos from both HR and the ethics department related to the company's privacy program. Both the volume and the duplication of information means that it is often ignored altogether.
Spencer said, "The company needs to dedicate itself to its privacy program and set regular in-person trainings for all staff once a month." Alice responded that the suggestion, while well-meaning, is not practical. With many locations, local HR departments need to have flexibility with their training schedules. Silently, Natalia agreed.
What is the most realistic step the organization can take to help diminish liability in the event of another incident?
Answer: A
Explanation:
This answer is the most realistic step the organization can take to help diminish liability in the event of another incident, as it can ensure that the vendor complies with the same standards and obligations as the organization regarding data protection. Vendor contracts should include clauses that specify the scope, purpose, duration and type of data processing, as well as the rights and responsibilities of both parties. The contracts should also require the vendor to implement appropriate technical and organizational measures to protect the data from unauthorized or unlawful access, use, disclosure, alteration or destruction, and to notify the organization of any security incidents or breaches. The contracts should also allow the organization to monitor, audit or inspect the vendor's performance and compliance with the contract terms and applicable laws and regulations. References: IAPP CIPM Study Guide, page 82; ISO/IEC 27002:2013, section 15.1.2
NEW QUESTION # 250
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