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| Section | Objectives |
|---|---|
| Assessing Data | - Manage vendor and third-party risks - Perform privacy impact assessments - Conduct data inventory and mapping |
| Establishing Governance | - Define roles and responsibilities - Create privacy policies and procedures - Establish reporting mechanisms |
| Developing a Framework | - Establish privacy governance structure - Define program scope and stakeholders - Identify applicable laws and frameworks |
| Protecting Personal Data | - Implement privacy and security controls - Handle cross-border data transfers - Manage data subject rights |
| Sustaining Program Performance | - Monitor and audit privacy program - Measure program effectiveness - Implement continuous improvement |
| Responding to Requests and Incidents | - Coordinate with regulators - Manage data breaches and incidents - Handle data subject requests |
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NEW QUESTION # 166
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 practice would afford the Director the most rigorous way to check on the program's compliance with laws, regulations and industry best practices?
Answer: D
NEW QUESTION # 167
SCENARIO
Please use the following to answer the next QUESTION:
It's just what you were afraid of. Without consulting you, the information technology director at your organization launched a new initiative to encourage employees to use personal devices for conducting business. The initiative made purchasing a new, high-specification laptop computer an attractive option, with discounted laptops paid for as a payroll deduction spread over a year of paychecks. The organization is also paying the sales taxes. It's a great deal, and after a month, more than half the organization's employees have signed on and acquired new laptops. Walking through the facility, you see them happily customizing and comparing notes on their new computers, and at the end of the day, most take their laptops with them, potentially carrying personal data to their homes or other unknown locations. It's enough to give you data- protection nightmares, and you've pointed out to the information technology Director and many others in the organization the potential hazards of this new practice, including the inevitability of eventual data loss or theft.
Today you have in your office a representative of the organization's marketing department who shares with you, reluctantly, a story with potentially serious consequences. The night before, straight from work, with laptop in hand, he went to the Bull and Horn Pub to play billiards with his friends. A fine night of sport and socializing began, with the laptop "safely" tucked on a bench, beneath his jacket. Later that night, when it was time to depart, he retrieved the jacket, but the laptop was gone. It was not beneath the bench or on another bench nearby. The waitstaff had not seen it. His friends were not playing a joke on him. After a sleepless night, he confirmed it this morning, stopping by the pub to talk to the cleanup crew. They had not found it.
The laptop was missing. Stolen, it seems. He looks at you, embarrassed and upset.
You ask him if the laptop contains any personal data from clients, and, sadly, he nods his head, yes. He believes it contains files on about 100 clients, including names, addresses and governmental identification numbers. He sighs and places his head in his hands in despair.
What should you do first to ascertain additional information about the loss of data?
Answer: C
Explanation:
This answer is the best way to ascertain additional information about the loss of data, as it allows you to gather relevant facts and details from the person who witnessed or experienced the incident. A standard protocol for interviewing the person reporting the incident should include questions such as:
* When and where did the incident occur?
* What type and amount of data was involved?
* How was the data stored or protected on the laptop?
* Who else had access to or knowledge of the laptop or the data?
* What actions have been taken so far to recover or secure the laptop or the data?
* How did you discover or report the incident?
* Do you have any evidence or clues about who may have taken or accessed the laptop or the data?
* Do you have any other information that may be relevant or helpful for the investigation? Interviewing the person reporting the incident following a standard protocol can help you to establish a clear timeline and scope of the incident, identify potential sources of evidence, assess the level of risk and harm to the individuals and the organization, and determine the next steps for responding to and resolving the incident. References: IAPP CIPM Study Guide, page 87; ISO/IEC 27002:2013, section 16.1.4
NEW QUESTION # 168
SCENARIO
Please use the following to answer the next question:
Edufox has hosted an annual convention of users of its famous e-learning software platform, and over time, it has become a grand event. It fills one of the large downtown conference hotels and overflows into the others, with several thousand attendees enjoying three days of presentations, panel discussions and networking. The convention is the centerpiece of the company's product rollout schedule and a great training opportunity for current users. The sales force also encourages prospective clients to attend to get a better sense of the ways in which the system can be customized to meet diverse needs and understand that when they buy into this system, they are joining a community that feels like family.
This year's conference is only three weeks away, and you have just heard news of a new initiative supporting it:
a smartphone app for attendees. The app will support late registration, highlight the featured presentations and provide a mobile version of the conference program. It also links to a restaurant reservation system with the best cuisine in the areas featured. "It's going to be great," the developer, Deidre Hoffman, tells you, "if, that is, we actually get it working!" She laughs nervously but explains that because of the tight time frame she'd been given to build the app, she outsourced the job to a local firm. "It's just three young people," she says, "but they do great work." She describes some of the other apps they have built. When asked how they were selected for this job, Deidre shrugs. "They do good work, so I chose them." Deidre is a terrific employee with a strong track record. That's why she's been charged to deliver this rushed project. You're sure she has the best interests of the company at heart, and you don't doubt that she's under pressure to meet a deadline that cannot be pushed back. However, you have concerns about the app's handling of personal data and its security safeguards. Over lunch in the break room, you start to talk to her about it, but she quickly tries to reassure you, "I'm sure with your help we can fix any security issues if we have to, but I doubt there'll be any. These people build apps for a living, and they know what they're doing. You worry too much, but that's why you're so good at your job!" You want to point out that normal protocols have not been followed in this matter. Which process in particular has been neglected?
Answer: D
NEW QUESTION # 169
Creating a privacy governance model for an organization that is required to appoint data protection officers under the GDPR poses what additional challenge?
Answer: D
NEW QUESTION # 170
Your marketing team wants to know why they need a check box for their SMS opt-in. You explain it is part of the consumer's right to?
Answer: D
Explanation:
Explanation
The marketing team needs a check box for their SMS opt-in because it is part of the consumer's right to be informed. This right means that consumers have the right to know how their personal data is collected, used, shared, and protected by the organization. The check box allows consumers to give their consent and opt-in to receive SMS messages from the organization, and also informs them of the purpose and scope of such messages. The other rights are not relevant in this case, as they are related to other aspects of data processing, such as correction, complaints, and access. References: CIPM Body of Knowledge, Domain IV: Privacy Program Communication, Section A: Communicating to Stakeholders, Subsection 1: Consumer Rights.
NEW QUESTION # 171
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