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| Section | Objectives |
|---|---|
| Sustaining Program Performance | - Measure program effectiveness - Implement continuous improvement - Monitor and audit privacy program |
| Protecting Personal Data | - Manage data subject rights - Handle cross-border data transfers - Implement privacy and security controls |
| Establishing Governance | - Establish reporting mechanisms - Create privacy policies and procedures - Define roles and responsibilities |
| Responding to Requests and Incidents | - Handle data subject requests - Coordinate with regulators - Manage data breaches and incidents |
| Assessing Data | - Conduct data inventory and mapping - Perform privacy impact assessments - Manage vendor and third-party risks |
| Developing a Framework | - Identify applicable laws and frameworks - Establish privacy governance structure - Define program scope and stakeholders |
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NEW QUESTION # 73
Which of the following is TRUE about a PIA (Privacy Impact Analysis)?
Answer: B
Explanation:
The results from a previous information audit can be leveraged in a PIA process. An information audit is a systematic review of the personal data that an organization holds, such as its sources, purposes, locations, flows, and retention periods. An information audit can provide valuable input for a PIA, as it can help identify the types and categories of personal data that will be involved in the project, as well as the potential risks and impacts associated with them. References: IAPP CIPM Study Guide, page 27.
NEW QUESTION # 74
When a data breach incident has occurred. the first priority is to determine?
Answer: C
Explanation:
Explanation
When a data breach incident has occurred, the first priority is to determine how to contain the breach.
Containment means stopping or minimizing the further loss or unauthorized disclosure of personal data, as well as preserving evidence for investigation and remediation. Containment may involve isolating affected systems, devices, or networks; changing access credentials; blocking malicious IP addresses; or notifying relevant parties such as law enforcement or security experts. After containing the breach, the next steps are to assess the impact and severity of the breach, notify the affected individuals and authorities if required, evaluate the causes and risks of the breach, and implement measures to prevent future breaches1, 2. References: CIPM
- International Association of Privacy Professionals, Free CIPM Study Guide - International Association of Privacy Professionals
NEW QUESTION # 75
SCENARIO
Please use the following to answer the next QUESTION:
Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can be used in the home to manage family calendars, do online shopping, and schedule doctor appointments.
After having had a successful launch in the United States, the Handy Helper is about to be made available for purchase worldwide.
The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the whole family, including children, but does not provide any further detail or privacy notice. In order to use the application, a family creates a single account, and the primary user has access to all information about the other users. Upon start up, the primary user must check a box consenting to receive marketing emails from Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.
Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European distributor of Handy Helper when he fielded many Questions about the product from the distributor. Sanjay needed to look more closely at the product in order to be able to answer the Questions as he was not involved in the product development process.
In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the product. This data is all stored in the cloud and is encrypted both during transmission and at rest.
Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent Omnimedia employees have access to user data under a program called Eureka. Omnipresent Omnimedia is hoping that at some point in the future, the data will reveal insights that could be used to create a fully automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is considered a long-term goal.
What can Sanjay do to minimize the risks of offering the product in Europe?
Answer: D
Explanation:
Sanjay should work with Manasa to review and remediate the Handy Helper as a gating item before it is released. This means that Sanjay should collaborate with Manasa and her product team to evaluate the privacy implications of the product and address any gaps or issues before launching it in Europe. This could involve conducting a PIA, applying the PbD principles, revising the consent mechanism, updating the privacy notice, ensuring compliance with data localization requirements, implementing data security measures, and limiting data access based on the least privilege principle. By doing so, Sanjay could help minimize the risks of offering the product in Europe and avoid potential violations of the General Data Protection Regulation (GDPR) or other local laws that could result in fines, lawsuits, or loss of trust.
NEW QUESTION # 76
SCENARIO
Please use the following to answer the next QUESTION:
As the Director of data protection for Consolidated Records Corporation, you are justifiably pleased with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of relatively minor data breaches that could easily have been worse. However, you have not had a reportable incident for the three years that you have been with the company. In fact, you consider your program a model that others in the data storage industry may note in their own program development.
You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward coherence across departments and throughout operations. You were aided along the way by the program's sponsor, the vice president of operations, as well as by a Privacy Team that started from a clear understanding of the need for change.
Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard" among both the executive team and frontline personnel working with data and interfacing with clients. Through the use of metrics that showed the costs not only of the breaches that had occurred, but also projections of the costs that easily could occur given the current state of operations, you soon had the leaders and key decision-makers largely on your side. Many of the other employees were more resistant, but face-to-face meetings with each department and the development of a baseline privacy training program achieved sufficient "buy-in" to begin putting the proper procedures into place.
Now, privacy protection is an accepted component of all current operations involving personal or protected data and must be part of the end product of any process of technological development. While your approach is not systematic, it is fairly effective.
You are left contemplating:
What must be done to maintain the program and develop it beyond just a data breach prevention program?
How can you build on your success?
What are the next action steps?
What process could most effectively be used to add privacy protections to a new, comprehensive program being developed at Consolidated?
Answer: C
NEW QUESTION # 77
What is the function of the privacy operational life cycle?
Answer: D
Explanation:
Explanation
The privacy operational life cycle is a process that allows the organization to respond to ever-changing privacy demands by continuously monitoring and improving the privacy program. It consists of four phases: assess, protect, sustain, and respond. Each phase involves different activities and outputs that help the organization identify and manage privacy risks and opportunities. References: IAPP CIPM Study Guide, page 14.
NEW QUESTION # 78
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