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| Section | Objectives |
|---|---|
| Sustaining Program Performance | - Monitor and audit privacy program - Measure program effectiveness - Implement continuous improvement |
| Assessing Data | - Perform privacy impact assessments - Conduct data inventory and mapping - Manage vendor and third-party risks |
| Responding to Requests and Incidents | - Handle data subject requests - Coordinate with regulators - Manage data breaches and incidents |
| Developing a Framework | - Define program scope and stakeholders - Identify applicable laws and frameworks - Establish privacy governance structure |
| Establishing Governance | - Establish reporting mechanisms - Create privacy policies and procedures - Define roles and responsibilities |
| Protecting Personal Data | - Manage data subject rights - Implement privacy and security controls - Handle cross-border data transfers |
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NEW QUESTION # 192
What is the main reason to begin with 3-5 key metrics during the program development process?
Answer: A
Explanation:
Explanation
This answer is the main reason to begin with 3-5 key metrics during the program development process, as it can help to align the privacy program with the organization's vision, mission and goals, and to measure the progress and performance of the program against these objectives. Key metrics are indicators that reflect the most important or critical aspects of the privacy program, such as compliance, risk, maturity, effectiveness or value. By starting with a small number of key metrics, the program development process can avoid being overwhelmed or distracted by too many or irrelevant data points, and can prioritize and concentrate on the areas that matter most for the organization.
NEW QUESTION # 193
MULTI-SELECT - Select 3
A multinational manufacturing company is considering outsourcing its HR data processing to a third-party vendor based in a country with less strict data protection laws. The company has a large database of employee information, including personal and sensitive data such as national ID numbers, medical information and employment contracts. The third-party vendor has a reputation for providing cost-effective services and has assured the company that it can handle the data securely.
The data protection officer (DPO) should ensure which of the following contractual requirements are included in the agreement with the third-party vendor?
Answer: A,C,D
Explanation:
CIPM requires that contracts with third-party processors include provisions addressing breach notification and response, mechanisms for lawful data transfers, and technical and organizational security measures
. Insurance coverage and cost reduction are business considerations and are not mandatory privacy contractual requirements.
NEW QUESTION # 194
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: D
NEW QUESTION # 195
SCENARIO
Please use the following to answer the next QUESTION:
Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new privacy officer. The company is based in California but thanks to some great publicity from a social media influencer last year, the company has received an influx of sales from the EU and has set up a regional office in Ireland to support this expansion. To become familiar with Ace Space's practices and assess what her privacy priorities will be, Penny has set up meetings with a number of colleagues to hear about the work that they have been doing and their compliance efforts.
Penny's colleague in Marketing is excited by the new sales and the company's plans, but is also concerned that Penny may curtail some of the growth opportunities he has planned. He tells her "I heard someone in the breakroom talking about some new privacy laws but I really don't think it affects us. We're just a small company. I mean we just sell accessories online, so what's the real risk?" He has also told her that he works with a number of small companies that help him get projects completed in a hurry. "We've got to meet our deadlines otherwise we lose money. I just sign the contracts and get Jim in finance to push through the payment. Reviewing the contracts takes time that we just don't have." In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken a number of precautions to protect its website from malicious activity, it has not taken the same level of care of its physical files or internal infrastructure. Penny's colleague in IT has told her that a former employee lost an encrypted USB key with financial data on it when he left. The company nearly lost access to their customer database last year after they fell victim to a phishing attack. Penny is told by her IT colleague that the IT team
"didn't know what to do or who should do what. We hadn't been trained on it but we're a small team though, so it worked out OK in the end." Penny is concerned that these issues will compromise Ace Space's privacy and data protection.
Penny is aware that the company has solid plans to grow its international sales and will be working closely with the CEO to give the organization a data "shake up". Her mission is to cultivate a strong privacy culture within the company.
Penny has a meeting with Ace Space's CEO today and has been asked to give her first impressions and an overview of her next steps.
To establish the current baseline of Ace Space's privacy maturity, Penny should consider all of the following factors EXCEPT?
Answer: C
Explanation:
The factor that Penny should not consider to establish the current baseline of Ace Space's privacy maturity is Ace Space's content sharing practices on social media. This is because this factor is not directly related to the privacy program elements that Penny should assess, such as leadership and organization, privacy risk management, engineering and information security, incident response, individual participation, transparency and redress, privacy training and awareness, and accountability1. The other factors are relevant to these elements and can help Penny measure the current state of Ace Space's privacy program against a recognized maturity model, such as the Privacy Capability Maturity Model (PCMM) developed by the Association of Corporate Counsel2. For example:
* Ace Space's documented procedures can help Penny evaluate the level of formalization and standardization of the privacy policies and practices across the organization, as well as the alignment with the applicable legal and regulatory requirements1, 2.
* Ace Space's employee training program can help Penny assess the level of awareness and competence of the staff on privacy issues and responsibilities, as well as the effectiveness and frequency of the training delivery and evaluation1, 2.
* Ace Space's vendor engagement protocols can help Penny determine the level of due diligence and oversight of the third parties that process personal data on behalf of Ace Space, as well as the contractual and technical safeguards that are in place to protect the data1, 2.
NEW QUESTION # 196
All of the following changes will likely trigger a data inventory update EXCEPT?
Answer: C
Explanation:
All of the changes listed will likely trigger a data inventory update except for the passage of a new privacy regulation. A data inventory is a record of all personal data that an organization collects, processes, stores, shares, or disposes of. A data inventory helps an organization understand what types of personal data it holds, where it comes from, where it goes, and how it is protected. A data inventory should be updated regularly to reflect any changes in the organization's data processing activities or practices. Some examples of changes that would trigger a data inventory update are outsourcing a business function, acquiring a new subsidiary, or onboarding a new vendor. These changes may involve new sources or destinations of personal data, new purposes or categories of processing, new security measures or risks, or new contractual agreements or obligations. The passage of a new privacy regulation may not trigger a data inventory update unless it affects the organization's existing data processing activities or practices. However, it may trigger a compliance assessment or gap analysis to determine if the organization needs to make any adjustments to its privacy program or policies to meet the new legal requirements. Reference: Data Inventory Hub; Data Inventory: What It Is & How To Create One
NEW QUESTION # 197
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