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| Section | Weight | Objectives |
|---|---|---|
| Protecting Personal Data | 12–18% | - Technical and organizational safeguards - Data lifecycle management - Cross-border data transfers - Privacy by design and default |
| Establishing Program Governance | 17–22% | - Stakeholder engagement and communication - Accountability and oversight mechanisms - Training and awareness programs - Policies, procedures and standards |
| Responding to Requests and Incidents | 14–18% | - Regulatory interaction and reporting - Breach detection, notification and remediation - Data subject rights management - Privacy incident response plan |
| Assessing Data and Privacy Risks | 17–22% | - Risk identification, analysis and mitigation - Data inventory and mapping - Privacy impact assessments (PIA/DPIA) - Compliance gap analysis |
| Sustaining Program Performance | 10–15% | - Monitoring, auditing and reporting - Change management - Performance metrics and KPIs - Continuous improvement |
| Developing a Privacy Program Framework | 15–20% | - Program governance structure and roles - Privacy vision, strategy and objectives - Legal and regulatory requirements - Program scope and boundaries |
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NEW QUESTION # 195
SCENARIO
Please use the following to answer the next QUESTION:
Richard McAdams recently graduated law school and decided to return to the small town of Lexington, Virginia to help run his aging grandfather's law practice. The elder McAdams desired a limited, lighter role in the practice, with the hope that his grandson would eventually take over when he fully retires. In addition to hiring Richard, Mr. McAdams employs two paralegals, an administrative assistant, and a part-time IT specialist who handles all of their basic networking needs. He plans to hire more employees once Richard gets settled and assesses the office's strategies for growth.
Immediately upon arrival, Richard was amazed at the amount of work that needed to done in order to modernize the office, mostly in regard to the handling of clients' personal data. His first goal is to digitize all the records kept in file cabinets, as many of the documents contain personally identifiable financial and medical data. Also, Richard has noticed the massive amount of copying by the administrative assistant throughout the day, a practice that not only adds daily to the number of files in the file cabinets, but may create security issues unless a formal policy is firmly in place Richard is also concerned with the overuse of the communal copier/ printer located in plain view of clients who frequent the building. Yet another area of concern is the use of the same fax machine by all of the employees. Richard hopes to reduce its use dramatically in order to ensure that personal data receives the utmost security and protection, and eventually move toward a strict Internet faxing policy by the year's end.
Richard expressed his concerns to his grandfather, who agreed, that updating data storage, data security, and an overall approach to increasing the protection of personal data in all facets is necessary Mr. McAdams granted him the freedom and authority to do so. Now Richard is not only beginning a career as an attorney, but also functioning as the privacy officer of the small firm. Richard plans to meet with the IT employee the following day, to get insight into how the office computer system is currently set-up and managed.
Which of the following policy statements needs additional instructions in order to further protect the personal data of their clients?
Answer: C
Explanation:
The policy statement that needs additional instructions in order to further protect the personal data of their clients is: All unused copies, prints, and faxes must be discarded in a designated recycling bin located near the work station and emptied daily. This policy statement is insufficient because it does not specify how the unused copies, prints, and faxes should be discarded. Simply throwing them into a recycling bin may expose them to unauthorized access or theft by anyone who has access to the bin or its contents. Furthermore, emptying the bin daily may not be frequent enough to prevent accumulation or overflow of sensitive documents.
To further protect the personal data of their clients, this policy statement should include additional instructions such as:
* All unused copies, prints, and faxes must be shredded before being discarded in a designated recycling bin located near the work station.
* The recycling bin must be locked or secured at all times when not in use.
* The recycling bin must be emptied at least twice a day or whenever it is full.
These additional instructions would ensure that the unused copies, prints, and faxes are destroyed in a secure manner and that the recycling bin is not accessible to unauthorized persons or prone to overflow.
The other policy statements do not need additional instructions, as they already provide adequate measures to protect the personal data of their clients. Documenting and double-checking the phone number for faxes ensures that the faxes are sent to the correct and intended recipient. Deleting the hard drives of copiers, printers, or fax machines before replacing or reselling them prevents data leakage or recovery by third parties.
Not leaving the information visible on the computer screen and retrieving the printed document immediately prevents data exposure or theft by anyone who can see the screen or access the printer.
NEW QUESTION # 196
Data retention and destruction policies should meet all of the following requirements EXCEPT?
Answer: B
Explanation:
Explanation
Documentation related to audit controls (third-party or internal) should be saved in a permanent format by default, not a non-permanent one. This is to ensure that the organization can demonstrate its compliance with the applicable laws and regulations, as well as its own policies and procedures, in case of an audit or a legal challenge. The other options are valid requirements for data retention and destruction policies, as they help to minimize the risks and costs associated with storing personal information beyond its intended purpose. References: CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task
3: Manage data retention and disposal.
NEW QUESTION # 197
The General Data Protection Regulation (GDPR) specifies fines that may be levied against data controllers for certain infringements. Which of the following will be subject to administrative fines of up to 10 000 000 EUR, or in the case of an undertaking, up to 2% of the total worldwide annual turnover of the preceding financial year?
Answer: A
Explanation:
Explanation/Reference: https://gdpr-info.eu/art-8-gdpr/
NEW QUESTION # 198
SCENARIO
Please use the following to answer the next QUESTION:
Edufox has hosted an annual convention of users of its famous e-learning software platform, and over time, it has become a grand event. It fills one of the large downtown conference hotels and overflows into the others, with several thousand attendees enjoying three days of presentations, panel discussions and networking. The convention is the centerpiece of the company's product rollout schedule and a great training opportunity for current users. The sales force also encourages prospective clients to attend to get a better sense of the ways in which the system can be customized to meet diverse needs and understand that when they buy into this system, they are joining a community that feels like family.
This year's conference is only three weeks away, and you have just heard news of a new initiative supporting it: a smartphone app for attendees. The app will support late registration, highlight the featured presentations and provide a mobile version of the conference program. It also links to a restaurant reservation system with the best cuisine in the areas featured. "It's going to be great," the developer, Deidre Hoffman, tells you, "if, that is, we actually get it working!" She laughs nervously but explains that because of the tight time frame she'd been given to build the app, she outsourced the job to a local firm. "It's just three young people," she says, "but they do great work." She describes some of the other apps they have built. When asked how they were selected for this job, Deidre shrugs. "They do good work, so I chose them." Deidre is a terrific employee with a strong track record. That's why she's been charged to deliver this rushed project. You're sure she has the best interests of the company at heart, and you don't doubt that she's under pressure to meet a deadline that cannot be pushed back. However, you have concerns about the app's handling of personal data and its security safeguards. Over lunch in the break room, you start to talk to her about it, but she quickly tries to reassure you, "I'm sure with your help we can fix any security issues if we have to, but I doubt there'll be any. These people build apps for a living, and they know what they're doing. You worry too much, but that's why you're so good at your job!" You see evidence that company employees routinely circumvent the privacy officer in developing new initiatives.
How can you best draw attention to the scope of this problem?
Answer: B
NEW QUESTION # 199
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.
Based on the scenario, Nationwide Grill needs to create better employee awareness of the company's privacy program by doing what?
Answer: A
NEW QUESTION # 200
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