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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Responding to Requests and Incidents | 14–18% | - Breach detection, notification and remediation - Data subject rights management - Privacy incident response plan - Regulatory interaction and reporting |
| Topic 2: Assessing Data and Privacy Risks | 17–22% | - Compliance gap analysis - Risk identification, analysis and mitigation - Privacy impact assessments (PIA/DPIA) - Data inventory and mapping |
| Topic 3: Developing a Privacy Program Framework | 15–20% | - Program scope and boundaries - Program governance structure and roles - Privacy vision, strategy and objectives - Legal and regulatory requirements |
| Topic 4: Establishing Program Governance | 17–22% | - Training and awareness programs - Stakeholder engagement and communication - Policies, procedures and standards - Accountability and oversight mechanisms |
| Topic 5: Protecting Personal Data | 12–18% | - Cross-border data transfers - Data lifecycle management - Technical and organizational safeguards - Privacy by design and default |
| Topic 6: Sustaining Program Performance | 10–15% | - Continuous improvement - Change management - Monitoring, auditing and reporting - Performance metrics and KPIs |
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NEW QUESTION # 32
Which is TRUE about the scope and authority of data protection oversight authorities?
Answer: C
NEW QUESTION # 33
(Which privacy by design foundational principle is described by the statement?)
Answer: D
Explanation:
The principle of full functionality - positive sum, not zero-sum emphasizes that privacy and business objectives do not need to be traded off against one another. CIPM teaches that effective privacy programs enable innovation, operational efficiency, and customer trust simultaneously.
This principle rejects the notion that privacy protections reduce functionality or business value. Instead, it promotes solutions that achieve all legitimate objectives. The statement explicitly reflects this philosophy by stating that privacy by design seeks to accommodate all legitimate interests rather than forcing unnecessary compromises. Other principles focus on defaults, transparency, or user respect, but only the positive-sum principle directly addresses balancing competing objectives without sacrifice.
NEW QUESTION # 34
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 analytic can be used to track the financial viability of the program as it develops?
Answer: D
NEW QUESTION # 35
Post-liquidation, a company that has acquired assets would require separate consent from a data subject if personally identifiable data were being retained for which purpose?
Answer: B
NEW QUESTION # 36
A minimum requirement for carrying out a Data Protection Impact Assessment (DPIA) would include?
Answer: D
Explanation:
Explanation
Processing on a large scale of special categories of data is a minimum requirement for carrying out a Data Protection Impact Assessment (DPIA) under the General Data Protection Regulation (GDPR). A DPIA is a type of Privacy Impact Assessment (PIA) that is specifically required by the GDPR when a processing activity is likely to result in a high risk to the rights and freedoms of natural persons. According to Article 35(3)(b) of the GDPR, a DPIA is mandatory when the processing involves a large scale of special categories of data or personal data relating to criminal convictions and offences. Special categories of data are personal data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life or sexual orientation. These types of data are considered more sensitive and require more protection, as they may pose higher risks of discrimination, identity theft, fraud, or other harms to the data subjects.
References:
* CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section C:
Monitoring and Managing Program Performance Subsection 1: Privacy Impact Assessments
* CIPM Study Guide (2021), Chapter 9: Monitoring and Managing Program Performance Section 9.1:
Privacy Impact Assessments
* CIPM Textbook (2019), Chapter 9: Monitoring and Managing Program Performance Section 9.1:
Privacy Impact Assessments
* CIPM Practice Exam (2021), Question 147
* GDPR Article 35(3)(b) and Article 9
NEW QUESTION # 37
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