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The CIPM Certification is geared towards privacy professionals who wish to gain a better understanding of the legal and regulatory frameworks surrounding data privacy. Among other things, those who hold this certification are well-versed in the laws and regulations that govern the collection, management, and use of customer data. They are also equipped to handle data breaches and work with their organizations to ensure compliance with these laws.
NEW QUESTION # 238
An organization's business continuity plan or disaster recovery plan does NOT typically include what?
Answer: B
NEW QUESTION # 239
What does it mean to "rationalize" data protection requirements?
Answer: B
Explanation:
To rationalize data protection requirements means to look for overlaps in laws and regulations from which a common solution can be developed. This can help simplify compliance efforts and reduce costs and complexity. References: IAPP CIPM Study Guide, page 16.
NEW QUESTION # 240
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.
How was Pacific Suites responsible for protecting the sensitive information of its offshoot, PHT?
Answer: D
NEW QUESTION # 241
SCENARIO
Please use the following to answer the next QUESTION:
Perhaps Jack Kelly should have stayed in the U.S. He enjoys a formidable reputation inside the company, Special Handling Shipping, for his work in reforming certain "rogue" offices. Last year, news broke that a police sting operation had revealed a drug ring operating in the Providence, Rhode Island office in the United States. Video from the office's video surveillance cameras leaked to news operations showed a drug exchange between Special Handling staff and undercover officers.
In the wake of this incident, Kelly had been sent to Providence to change the "hands off" culture that upper management believed had let the criminal elements conduct their illicit transactions. After a few weeks under Kelly's direction, the office became a model of efficiency and customer service. Kelly monitored his workers' activities using the same cameras that had recorded the illegal conduct of their former co-workers.
Now Kelly has been charged with turning around the office in Cork, Ireland, another trouble spot. The company has received numerous reports of the staff leaving the office unattended. When Kelly arrived, he found that even when present, the staff often spent their days socializing or conducting personal business on their mobile phones. Again, he observed their behaviors using surveillance cameras. He issued written reprimands to six staff members based on the first day of video alone.
Much to Kelly's surprise and chagrin, he and the company are now under investigation by the Data Protection Commissioner of Ireland for allegedly violating the privacy rights of employees. Kelly was told that the company's license for the cameras listed facility security as their main use, but he does not know why this matters. He has pointed out to his superiors that the company's training programs on privacy protection and data collection mention nothing about surveillance video.
You are a privacy protection consultant, hired by the company to assess this incident, report on the legal and compliance issues, and recommend next steps.
What should you advise this company regarding the status of security cameras at their offices in the United States?
Answer: A
Explanation:
Explanation
This answer is the best way to advise this company regarding the status of security cameras at their offices in the United States, as it can help to protect the privacy and security of the employees and visitors who are recorded by the cameras, as well as to comply with any applicable laws and regulations that may limit or regulate the use of surveillance video. Restricting access to surveillance video means that only authorized personnel who have a legitimate business need can view, copy, share or disclose the video, and that they must follow proper procedures and safeguards to prevent unauthorized or unlawful access, use or disclosure.
Destroying the recordings after a designated period of time means that the video is not kept longer than necessary for the purpose for which it was collected, and that it is disposed of securely and irreversibly. The designated period of time should be based on the legal, operational and risk factors that may affect the retention of the video, such as potential litigation, investigations, audits or claims. References: IAPP CIPM Study Guide, page 831; ISO/IEC 27002:2013, section 8.3.2
NEW QUESTION # 242
A Human Resources director at a company reported that a laptop containing employee payroll data was lost on the train. Which action should the company take IMMEDIATELY?
Answer: D
Explanation:
The company should perform a multi-factor risk analysis immediately after discovering the loss of the laptop containing employee payroll data. A multi-factor risk analysis is a process of assessing the potential impact and likelihood of a data breach, taking into account various factors such as the nature, scope, context, and purpose of the processing, the type and severity of the harm that may result from the breach, the number and categories of data subjects and personal data affected, the measures taken to mitigate the risk, and any relevant legal obligations or codes of conduct. A multi-factor risk analysis can help the company determine whether the breach poses a high risk to the rights and freedoms of the data subjects, and whether it needs to notify them and/or the relevant supervisory authority without undue delay, as required by Article 33 and 34 of the GDPR1. A multi-factor risk analysis can also help the company identify the root cause of the breach, evaluate the effectiveness of its existing security measures, and implement appropriate corrective actions to prevent or minimize similar incidents in the future.
References:
CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section B:
Protecting Personal Information, Subsection 2: Data Breach Incident Planning and Management2 CIPM Study Guide (2021), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management3 CIPM Textbook (2019), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management4 CIPM Practice Exam (2021), Question 1285 GDPR Article 33 and 341
NEW QUESTION # 243
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