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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: Sustaining Program Performance | 10–15% | - Monitoring, auditing and reporting - Continuous improvement - Change management - Performance metrics and KPIs |
| Topic 3: Responding to Requests and Incidents | 14–18% | - Regulatory interaction and reporting - Breach detection, notification and remediation - Data subject rights management - Privacy incident response plan |
| Topic 4: Protecting Personal Data | 12–18% | - Cross-border data transfers - Data lifecycle management - Technical and organizational safeguards - Privacy by design and default |
| Topic 5: Assessing Data and Privacy Risks | 17–22% | - Data inventory and mapping - Risk identification, analysis and mitigation - Compliance gap analysis - Privacy impact assessments (PIA/DPIA) |
| Topic 6: Establishing Program Governance | 17–22% | - Policies, procedures and standards - Training and awareness programs - Stakeholder engagement and communication - Accountability and oversight mechanisms |
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NEW QUESTION # 117
Which of the following best supports implementing controls to bring privacy policies into effect?
Answer: D
Explanation:
The information technology (IT) group supporting and enhancing the privacy program and privacy policy by developing processes and controls best supports implementing controls to bring privacy policies into effect. Privacy policies are documents that define the organization's principles, commitments, and practices for collecting, using, disclosing, retaining, and protecting personal information. Privacy policies need to be translated into operational processes and controls that ensure compliance with the policy objectives and requirements. The IT group can support and enhance the privacy program and privacy policy by developing processes and controls such as: data classification, data inventory, data mapping, data minimization, consent management, access control, encryption, pseudonymization, anonymization, security safeguards, breach detection and response, data subject rights fulfillment, data retention and disposal, audit logging and monitoring, privacy by design and default, privacy impact assessments, privacy notices and statements, privacy training and awareness.
Reference:
CIPM Body of Knowledge (2021), Domain II: Privacy Program Framework, Section A: Privacy Program Framework Components Subsection 1: Privacy Policies CIPM Study Guide (2021), Chapter 4: Privacy Program Framework Components Section 4.1: Privacy Policies CIPM Textbook (2019), Chapter 4: Privacy Program Framework Components Section 4.1: Privacy Policies CIPM Practice Exam (2021), Question 148
NEW QUESTION # 118
SCENARIO
Please use the following to answer the next question:
Martin Briseno is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseno decided to change the hotel's on-the-job mentoring model to a standardized training program for employees who were progressing from line positions into supervisory positions. He developed a curriculum comprising a series of lessons, scenarios, and assessments, which was delivered in-person to small groups. Interest in the training increased, leading Briseno to work with corporate HR specialists and software engineers to offer the program in an online format. The online program saved the cost of a trainer and allowed participants to work through the material at their own pace.
Upon hearing about the success of Briseno's program, Pacific Suites corporate Vice President Maryanne Silva-Hayes expanded the training and offered it company-wide. Employees who completed the program received certification as a Pacific Suites Hospitality Supervisor. By 2001, the program had grown to provide industry-wide training. Personnel at hotels across the country could sign up and pay to take the course online.
As the program became increasingly profitable, Pacific Suites developed an offshoot business, Pacific Hospitality Training (PHT). The sole focus of PHT was developing and marketing a variety of online courses and course progressions providing a number of professional certifications in the hospitality industry.
By setting up a user account with PHT, course participants could access an information library, sign up for courses, and take end-of-course certification tests. When a user opened a new account, all information was saved by default, including the user's name, date of birth, contact information, credit card information, employer, and job title. The registration page offered an opt-out choice that users could click to not have their credit card numbers saved. Once a user name and password were established, users could return to check their course status, review and reprint their certifications, and sign up and pay for new courses. Between 2002 and
2008, PHT issued more than 700,000 professional certifications.
PHT's profits declined in 2009 and 2010, the victim of industry downsizing and increased competition from e- learning providers. By 2011, Pacific Suites was out of the online certification business and PHT was dissolved.
The training program's systems and records remained in Pacific Suites' digital archives, un-accessed and unused. Briseno and Silva-Hayes moved on to work for other companies, and there was no plan for handling the archived data after the program ended. After PHT was dissolved, Pacific Suites executives turned their attention to crucial day-to-day operations. They planned to deal with the PHT materials once resources allowed.
In 2012, the Pacific Suites computer network was hacked. Malware installed on the online reservation system exposed the credit card information of hundreds of hotel guests. While targeting the financial data on the reservation site, hackers also discovered the archived training course data and registration accounts of Pacific Hospitality Training's customers. The result of the hack was the exfiltration of the credit card numbers of recent hotel guests and the exfiltration of the PHT database with all its contents.
A Pacific Suites systems analyst discovered the information security breach in a routine scan of activity reports. Pacific Suites quickly notified credit card companies and recent hotel guests of the breach, attempting to prevent serious harm. Technical security engineers faced a challenge in dealing with the PHT data.
PHT course administrators and the IT engineers did not have a system for tracking, cataloguing, and storing information. Pacific Suites has procedures in place for data access and storage, but those procedures were not implemented when PHT was formed. When the PHT database was acquired by Pacific Suites, it had no owner or oversight. By the time technical security engineers determined what private information was compromised, at least 8,000 credit card holders were potential victims of fraudulent activity.
What must Pacific Suite's primary focus be as it manages this security breach?
Answer: A
NEW QUESTION # 119
Which of the following is NOT a type of privacy program metric?
Answer: A
Explanation:
Explanation
Types of privacy program metrics include business enablement metrics, data enhancement metrics, and commercial metrics. Business enablement metrics measure the effectiveness of the privacy program in enabling the business to function without compromising privacy. Data enhancement metrics measure the effectiveness of the privacy program in enhancing data protection, such as through data minimization, access controls, and data security. Commercial metrics measure the effectiveness of the privacy program in creating value, such as through the development of new products, services, and customer experiences.
Privacy program metrics are used to assess the effectiveness of a privacy program and measure its progress.
These metrics can include business enablement metrics, data enhancement metrics, and commercial metrics.
Value creation metrics, however, are not typically used as privacy program metrics.
NEW QUESTION # 120
Formosa International operates in 20 different countries including the United States and France. What organizational approach would make complying with a number of different regulations easier?
Answer: C
Explanation:
Rationalizing requirements is an organizational approach that involves identifying and harmonizing the common elements of different privacy regulations and standards. This can make compliance easier and more efficient, as well as reduce the risk of conflicts or gaps in privacy protection. Rationalizing requirements can also help to create a consistent privacy policy and culture across different jurisdictions and business units. References: CIPM Study Guide, page 23.
NEW QUESTION # 121
An organization's business continuity plan or disaster recovery plan does NOT typically include what?
Answer: A
NEW QUESTION # 122
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