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| Section | Weight | Objectives |
|---|---|---|
| Protecting Personal Data | 12–18% | - Data lifecycle management - Technical and organizational safeguards - Privacy by design and default - Cross-border data transfers |
| Establishing Program Governance | 17–22% | - Policies, procedures and standards - Stakeholder engagement and communication - Accountability and oversight mechanisms - Training and awareness programs |
| Sustaining Program Performance | 10–15% | - Continuous improvement - Monitoring, auditing and reporting - Performance metrics and KPIs - Change management |
| Developing a Privacy Program Framework | 15–20% | - Privacy vision, strategy and objectives - Program governance structure and roles - Legal and regulatory requirements - Program scope and boundaries |
| Assessing Data and Privacy Risks | 17–22% | - Privacy impact assessments (PIA/DPIA) - Data inventory and mapping - Risk identification, analysis and mitigation - Compliance gap analysis |
| Responding to Requests and Incidents | 14–18% | - Data subject rights management - Breach detection, notification and remediation - Privacy incident response plan - Regulatory interaction and reporting |
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NEW QUESTION # 225
SCENARIO
Please use the following to answer the next QUESTION:
Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner, Anton, has found some degree of disorganization after touring the company headquarters. His uncle Henry had always focused on production - not data processing - and Anton is concerned. In several storage rooms, he has found paper files, disks, and old computers that appear to contain the personal data of current and former employees and customers. Anton knows that a single break-in could irrevocably damage the company's relationship with its loyal customers. He intends to set a goal of guaranteed zero loss of personal information.
To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of the company. However, Kenneth - his uncle's vice president and longtime confidante - wants to hold off on Anton's idea in favor of converting any paper records held at the company to electronic storage. Kenneth believes this process would only take one or two years. Anton likes this idea; he envisions a password- protected system that only he and Kenneth can access.
Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier, but it will simplify the management of the stored dat a. The heads of subsidiaries like the art gallery and kitchenware store down the street will be responsible for their own information management. Then, any unneeded subsidiary data still in Anton's possession can be destroyed within the next few years.
After learning of a recent security incident, Anton realizes that another crucial step will be notifying customers. Kenneth insists that two lost hard drives in Question are not cause for concern; all of the data was encrypted and not sensitive in nature. Anton does not want to take any chances, however. He intends on sending notice letters to all employees and customers to be safe.
Anton must also check for compliance with all legislative, regulatory, and market requirements related to privacy protection. Kenneth oversaw the development of the company's online presence about ten years ago, but Anton is not confident about his understanding of recent online marketing laws. Anton is assigning another trusted employee with a law background the task of the compliance assessment. After a thorough analysis, Anton knows the company should be safe for another five years, at which time he can order another check.
Documentation of this analysis will show auditors due diligence.
Anton has started down a long road toward improved management of the company, but he knows the effort is worth it. Anton wants his uncle's legacy to continue for many years to come.
Which important principle of Data Lifecycle Management (DLM) will most likely be compromised if Anton executes his plan to limit data access to himself and Kenneth?
Answer: A
Explanation:
The important principle of Data Lifecycle Management (DLM) that will most likely be compromised if Anton executes his plan to limit data access to himself and Kenneth is ensuring data retrievability. Data retrievability refers to the ability to access and use data when needed for business purposes or legal obligations1 It involves maintaining the availability, integrity, and usability of data throughout its lifecycle2 However, if Anton restricts data access to only himself and Kenneth, he will create a single point of failure and a bottleneck for data retrieval. This could pose several risks and challenges for the company, such as:
Losing data if Anton or Kenneth forgets the password or leaves the company without sharing it with others.
Delaying data retrieval if Anton or Kenneth is unavailable or unresponsive when someone else needs the data urgently.
Violating data protection laws or regulations that require data access by certain parties or authorities under certain circumstances.
Reducing data quality or accuracy if Anton or Kenneth fails to update or maintain the data properly.
Missing business opportunities or insights if Anton or Kenneth does not share the data with other relevant stakeholders or departments.
Therefore, Anton should reconsider his plan and adopt a more balanced and secure approach to data access management that follows the principle of least privilege. This means granting data access only to those who need it for their specific roles and responsibilities and revoking it when no longer needed3 He should also implement proper authentication, authorization, encryption, backup, and audit mechanisms to protect the data from unauthorized or unlawful access, use, disclosure, alteration, or destruction4 Reference: 1: Data Retrievability: What Is It?; 2: Data Lifecycle Management | IBM; 3: What is Least Privilege? Definition & Examples; 4: Technical Security Controls: Encryption, Firewalls & More
NEW QUESTION # 226
If an organization maintains a separate ethics office, to whom would its officer typically report to in order to retain the greatest degree of independence?
Answer: D
Explanation:
Explanation
If an organization maintains a separate ethics office, its officer would typically report to the Board of Directors in order to retain the greatest degree of independence. This is because the Board of Directors is the highest governing body of the organization and has the authority and responsibility to oversee the ethical conduct and performance of the organization and its management1 Reporting to the Board of Directors would enable the ethics officer to avoid any potential conflicts of interest or undue influence from other senior executives or managers who may have a stake in the ethical issues or decisions that the ethics office handles2 Reporting to the Board of Directors would also enhance the credibility and legitimacy of the ethics office and its recommendations, as well as demonstrate the organization's commitment to ethical values and culture3 The other options are not as suitable as reporting to the Board of Directors for retaining the greatest degree of independence for the ethics office. Reporting to the Chief Financial Officer may create a conflict of interest or a perception of bias if the ethical issues or decisions involve financial matters or implications4 Reporting to the Human Resources Director may limit the scope or authority of the ethics office to deal with ethical issues or decisions that go beyond human resources policies or practices5 Reporting to the organization's General Counsel may blur the distinction or create confusion between legal compliance and ethical conduct, as well as raise concerns about attorney-client privilege or confidentiality6 References: 1: Board Responsibilities | BoardSource; 2: Ethics Officer: Job Description, Duties and Requirements; 3: The Role Of The Ethics And Compliance Officer In The 21st Century | Corporate Compliance Insights; 4: Ethics Officer: Job Description, Duties and Requirements; 5: Ethics Officer: Job Description, Duties and Requirements; 6: Ethics Officer: Job Description, Duties and Requirements
NEW QUESTION # 227
SCENARIO
Please use the following to answer the next QUESTION:
Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can be used in the home to manage family calendars, do online shopping, and schedule doctor appointments. After having had a successful launch in the United States, the Handy Helper is about to be made available for purchase worldwide.
The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the whole family, including children, but does not provide any further detail or privacy notice. In order to use the application, a family creates a single account, and the primary user has access to all information about the other users. Upon start up, the primary user must check a box consenting to receive marketing emails from Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.
Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European distributor of Handy Helper when he fielded many Questions about the product from the distributor. Sanjay needed to look more closely at the product in order to be able to answer the Questions as he was not involved in the product development process.
In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the product. This data is all stored in the cloud and is encrypted both during transmission and at rest.
Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent Omnimedia employees have access to user data under a program called Eurek a. Omnipresent Omnimedia is hoping that at some point in the future, the data will reveal insights that could be used to create a fully automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is considered a long-term goal.
What step in the system development process did Manasa skip?
Answer: C
NEW QUESTION # 228
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.
What metric can Goddard use to assess whether costs associated with implementing new privacy protections are justified?
Answer: D
NEW QUESTION # 229
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 dat a. 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.
The company may start to earn back the trust of its customer base by following Albert's suggestion regarding which handling procedure?
Answer: B
Explanation:
This answer is the best way to describe the handling procedure that Albert suggests and that may help the company to earn back the trust of its customer base, as it involves creating a toll-free number for customers, as well as a more efficient procedure for responding to customer concerns by postal mail. Correction is a handling procedure that allows customers to request that the company updates, modifies or deletes their personal data if it is inaccurate, incomplete or outdated. Correction can help to enhance the quality and integrity of the data, as well as to respect the rights and preferences of the customers. Correction can also help to improve the customer satisfaction and loyalty, as well as to prevent or reduce any errors or disputes that may arise from incorrect or outdated data.
NEW QUESTION # 230
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