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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Operational Life Cycle of a Privacy Program | 50% | - Implementing privacy controls and procedures - Managing data inventory and data flows - Monitoring, auditing, and continuous improvement - Assessing privacy risks and impacts |
| Topic 2: Privacy Program Governance | 50% | - Policy development and implementation - Metrics, reporting, and accountability - Stakeholder engagement and communication - Privacy program structure and governance models |
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NEW QUESTION # 52
SCENARIO
Please use the following to answer the next QUESTION:
As they company's new chief executive officer, Thomas Goddard wants to be known as a leader in data protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically Questionable practices, including unauthorized sales of personal data to marketers.
Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company's claims that
"appropriate" data protection safeguards were in place. The scandal affected the company's business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard's mentor, was forced to step down.
Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company's board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures.
He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. "We want Medialite to have absolutely the highest standards," he says. "In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company's finances. So, while I want the best solutions across the board, they also need to be cost effective." You are told to report back in a week's time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.
The company has achieved a level of privacy protection that established new best practices for the industry.
What is a logical next step to help ensure a high level of protection?
Answer: C
Explanation:
Shifting attention to privacy for emerging technologies as the company begins to use them is a logical next step to help ensure a high level of protection. Emerging technologies, such as artificial intelligence, biometrics, blockchain, cloud computing, internet of things, etc., may pose new challenges and opportunities for privacy and data protection. They may involve new types, sources, uses, and flows of personal data that require different or additional safeguards and controls. They may also introduce new risks or impacts for individuals' rights and interests that require careful assessment and mitigation. Therefore, it is important for the company to consider and address the privacy implications of emerging technologies as they adopt or integrate them into their products, services, or processes.
The other options are not as logical or effective as shifting attention to privacy for emerging technologies for ensuring a high level of protection. Brainstorming methods for developing an enhanced privacy framework may not be necessary or feasible if the company already has established new best practices for the industry.
Developing a strong marketing strategy to communicate the company's privacy practices may not be sufficient or relevant for ensuring a high level of protection, as it may not reflect the actual state or quality of the privacy program. Focusing on improving the incident response plan in preparation for any breaks in protection may be too reactive or narrow in scope, as it may not cover other aspects or dimensions of privacy and data protection that require continuous monitoring and improvement.
For more information on privacy for emerging technologies, you can refer to these sources:
* [Privacy by Design in Emerging Technologies]
* [Privacy Challenges in Emerging Technologies]
* [Privacy Enhancing Technologies]
NEW QUESTION # 53
SCENARIO
Please use the following to answer the next QUESTION:
Amira is thrilled about the sudden expansion of NatGen. As the joint Chief Executive Officer (CEO) with her long-time business partner Sadie, Amira has watched the company grow into a major competitor in the green energy market. The current line of products includes wind turbines, solar energy panels, and equipment for geothermal systems. A talented team of developers means that NatGen's line of products will only continue to grow.
With the expansion, Amira and Sadie have received advice from new senior staff members brought on to help manage the company's growth. One recent suggestion has been to combine the legal and security functions of the company to ensure observance of privacy laws and the company's own privacy policy. This sounds overly complicated to Amira, who wants departments to be able to use, collect, store, and dispose of customer data in ways that will best suit their needs. She does not want administrative oversight and complex structuring to get in the way of people doing innovative work.
Sadie has a similar outlook. The new Chief Information Officer (CIO) has proposed what Sadie believes is an unnecessarily long timetable for designing a new privacy program. She has assured him that NatGen will use the best possible equipment for electronic storage of customer and employee data. She simply needs a list of equipment and an estimate of its cost. But the CIO insists that many issues are necessary to consider before the company gets to that stage.
Regardless, Sadie and Amira insist on giving employees space to do their jobs. Both CEOs want to entrust the monitoring of employee policy compliance to low-level managers. Amira and Sadie believe these managers can adjust the company privacy policy according to what works best for their particular departments. NatGen's CEOs know that flexible interpretations of the privacy policy in the name of promoting green energy would be highly unlikely to raise any concerns with their customer base, as long as the data is always used in course of normal business activities.
Perhaps what has been most perplexing to Sadie and Amira has been the CIO's recommendation to institute a privacy compliance hotline. Sadie and Amira have relented on this point, but they hope to compromise by allowing employees to take turns handling reports of privacy policy violations. The implementation will be easy because the employees need no special preparation. They will simply have to document any concerns they hear.
Sadie and Amira are aware that it will be challenging to stay true to their principles and guard against corporate culture strangling creativity and employee morale. They hope that all senior staff will see the benefit of trying a unique approach.
If Amira and Sadie's ideas about adherence to the company's privacy policy go unchecked, the Federal Communications Commission (FCC) could potentially take action against NatGen for what?
Answer: A
Explanation:
Explanation
If Amira and Sadie's ideas about adherence to the company's privacy policy go unchecked, the Federal Communications Commission (FCC) could potentially take action against NatGen for deceptive practices.
This is because the FCC has the authority to enforce Section 5 of the Federal Trade Commission Act, which prohibits unfair or deceptive acts or practices in or affecting commerce. By allowing different departments to use, collect, store, and dispose of customer data in ways that may not be consistent with the company's privacy policy, NatGen may be misleading its customers about how their personal information is protected and used.
This could violate the FTC Act and expose NatGen to enforcement actions, fines, and reputational damage. References: [FCC Enforcement], [FTC Act], [Privacy Policy]
NEW QUESTION # 54
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.
What is the best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has?
Answer: A
Explanation:
Explanation
The best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has is to analyze the data inventory to map data flows. A data inventory is a comprehensive record of the personal data that an organization collects, stores, uses and shares. It helps to identify the sources, categories, locations, recipients and retention periods of personal data. A data flow map is a visual representation of how personal data flows within and outside an organization. It helps to identify the data transfers, processing activities, legal bases, risks and safeguards of personal data.
By analyzing the data inventory and mapping the data flows, Penny can gain a clear picture of the personal data lifecycle at Ace Space and identify any gaps or issues that need to be addressed. For example, she can determine whether Ace Space has a lawful basis for processing personal data of EU customers, whether it has adequate security measures to protect personal data from unauthorized access or loss, whether it has appropriate contracts with its vendors and cloud providers to ensure compliance with applicable laws and regulations, and whether it has mechanisms to respect the rights and preferences of its customers.
The other options are not the best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has. Auditing all vendors' privacy practices and safeguards (B) is an important step to ensure that Ace Space's third-party processors are complying with their contractual obligations and legal requirements, but it does not provide a comprehensive overview of Ace Space's own personal data processing activities. Conducting a Privacy Impact Assessment (PIA) for the company is a useful tool to assess the privacy risks and impacts of a specific project or initiative involving personal data, but it does not provide a baseline understanding of the existing personal data landscape at Ace Space. Reviewing all cloud contracts to identify the location of data servers used (D) is a relevant aspect of understanding the location of personal data, but it does not cover other aspects such as classification and processing purpose.
References:
* CIPM Body of Knowledge Domain I: Privacy Program Governance - Task 1: Establish privacy program vision and strategy - Subtask 1: Identify applicable privacy laws, regulations and standards
* CIPM Body of Knowledge Domain II: Privacy Program Operational Life Cycle - Task 1: Assess current state of privacy in an organization - Subtask 1: Conduct gap analysis
* CIPM Study Guide - Chapter 2: Privacy Program Governance - Section 2.1: Data Inventory
* CIPM Study Guide - Chapter 2: Privacy Program Governance - Section 2.2: Data Flow Mapping
NEW QUESTION # 55
SCENARIO
Please use the following to answer the next QUESTION:
Your organization, the Chicago (U.S.)-based Society for Urban Greenspace, has used the same vendor to operate all aspects of an online store for several years. As a small nonprofit, the Society cannot afford the higher-priced options, but you have been relatively satisfied with this budget vendor, Shopping Cart Saver (SCS). Yes, there have been some issues. Twice, people who purchased items from the store have had their credit card information used fraudulently subsequent to transactions on your site, but in neither case did the investigation reveal with certainty that the Society's store had been hacked. The thefts could have been employee-related.
Just as disconcerting was an incident where the organization discovered that SCS had sold information it had collected from customers to third parties. However, as Jason Roland, your SCS account representative, points out, it took only a phone call from you to clarify expectations and the "misunderstanding" has not occurred again.
As an information-technology program manager with the Society, the role of the privacy professional is only one of many you play. In all matters, however, you must consider the financial bottom line. While these problems with privacy protection have been significant, the additional revenues of sales of items such as shirts and coffee cups from the store have been significant. The Society's operating budget is slim, and all sources of revenue are essential.
Now a new challenge has arisen. Jason called to say that starting in two weeks, the customer data from the store would now be stored on a data cloud. "The good news," he says, "is that we have found a low-cost provider in Finland, where the data would also be held. So, while there may be a small charge to pass through to you, it won't be exorbitant, especially considering the advantages of a cloud." Lately, you have been hearing about cloud computing and you know it's fast becoming the new paradigm for various applications. However, you have heard mixed reviews about the potential impacts on privacy protection. You begin to research and discover that a number of the leading cloud service providers have signed a letter of intent to work together on shared conventions and technologies for privacy protection. You make a note to find out if Jason's Finnish provider is signing on.
What is the best way for your vendor to be clear about the Society's breach notification expectations?
Answer: C
Explanation:
Explanation
This answer is the best way for Albert's vendor to be clear about the Society's breach notification expectations, as it can establish clear and binding terms and conditions for both parties regarding their roles and responsibilities for handling any data security incidents or breaches. Including notification provisions in the vendor contract can help to define what constitutes a breach, how it should be detected, reported and investigated, what information should be provided to the organization and within what time frame, what actions should be taken to mitigate or resolve the breach, and what consequences or liabilities may arise from the breach. The contract can also specify that the vendor must cooperate and coordinate with the organization in any breach notification activities to the relevant authorities, customers, partners or stakeholders.
NEW QUESTION # 56
SCENARIO
Please use the following to answer the next question
You were recently hired by InStyte Date Corp as a privacy manager to help InStyle Data Corp become compliant with a new data protection law The law mandates that businesses have reasonable and appropriate security measures in place to protect personal data. Violations of that mandate are heavily fined and the legislators have stated that they will aggressively pursue companies that don t comply with the new law You are paved with a security manager and tasked with reviewing InStyle Data Corp s current state and advising the business how it can meet the "reasonable and appropriate security" requirement InStyle Data Corp has grown rapidly and has not kept a data inventory or completed a data mapping InStyte Data Corp has also developed security-related policies ad hoc and many have never been implemented The various teams involved in the creation and testing of InStyle Data Corp s products experience significant turnover and do not have well defined roles There's little documentation addressing what personal data is processed by which product and for what purpose Work needs to begin on this project immediately so that InStyle Data Corp can become compliant by the time the law goes into effect. You and you partner discover that InStyle Data Corp regularly sends files containing sensitive personal data back to its customers through email sometimes using InStyle Data Corp employees personal email accounts. You also team that InStyle Data Corp s privacy and information security teams are not informed of new personal data flows, new products developed by InStyte Data Corp that process personal data, or updates to existing InStyle Data Corp products that may change what or how the personal data is processed until after the product or update has gone have.
Through a review of InStyle Date Corp's test and development environment logs, you discover InStyle Data Corp sometimes gives login credentials to any InStyle Data Corp employee or contractor who requests them.
The test environment only contains dummy data but the development environment contains personal data including Social Security Numbers, hearth
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