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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Protecting Personal Data | 12–18% | - Cross-border data transfers - Privacy by design and default - Technical and organizational safeguards - Data lifecycle management |
| Topic 2: Developing a Privacy Program Framework | 15–20% | - Privacy vision, strategy and objectives - Legal and regulatory requirements - Program scope and boundaries - Program governance structure and roles |
| Topic 3: Sustaining Program Performance | 10–15% | - Performance metrics and KPIs - Monitoring, auditing and reporting - Change management - Continuous improvement |
| Topic 4: Establishing Program Governance | 17–22% | - Accountability and oversight mechanisms - Training and awareness programs - Stakeholder engagement and communication - Policies, procedures and standards |
| Topic 5: Responding to Requests and Incidents | 14–18% | - Data subject rights management - Breach detection, notification and remediation - Privacy incident response plan - Regulatory interaction and reporting |
| Topic 6: Assessing Data and Privacy Risks | 17–22% | - Data inventory and mapping - Privacy impact assessments (PIA/DPIA) - Risk identification, analysis and mitigation - Compliance gap analysis |
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NEW QUESTION # 90
You would like your organization to be independently audited to demonstrate compliance with international privacy standards and to identify gaps for remediation.
Which type of audit would help you achieve this objective?
Answer: C
NEW QUESTION # 91
SCENARIO
Please use the following to answer the next QUESTION:
John is the new privacy officer at the prestigious international law firm - A&M LLP. A&M LLP is very proud of its reputation in the practice areas of Trusts & Estates and Merger & Acquisition in both U.S. and Europe.
During lunch with a colleague from the Information Technology department, John heard that the Head of IT, Derrick, is about to outsource the firm's email continuity service to their existing email security vendor - MessageSafe. Being successful as an email hygiene vendor, MessageSafe is expanding its business by leasing cloud infrastructure from Cloud Inc. to host email continuity service for A&M LLP.
John is very concerned about this initiative. He recalled that MessageSafe was in the news six months ago due to a security breach. Immediately, John did a quick research of MessageSafe's previous breach and learned that the breach was caused by an unintentional mistake by an IT administrator. He scheduled a meeting with Derrick to address his concerns.
At the meeting, Derrick emphasized that email is the primary method for the firm's lawyers to communicate with clients, thus it is critical to have the email continuity service to avoid any possible email downtime.
Derrick has been using the anti-spam service provided by MessageSafe for five years and is very happy with the quality of service provided by MessageSafe. In addition to the significant discount offered by MessageSafe, Derrick emphasized that he can also speed up the onboarding process since the firm already has a service contract in place with MessageSafe. The existing on-premises email continuity solution is about to reach its end of life very soon and he doesn't have the time or resource to look for another solution.
Furthermore, the off-premises email continuity service will only be turned on when the email service at A&M LLP's primary and secondary data centers are both down, and the email messages stored at MessageSafe site for continuity service will be automatically deleted after 30 days.
Which of the following is the most effective control to enforce MessageSafe's implementation of appropriate technical countermeasures to protect the personal data received from A&M LLP?
Answer: A
Explanation:
The most effective control to enforce MessageSafe's implementation of appropriate technical countermeasures to protect the personal data received from A&M LLP is to require MessageSafe to apply appropriate security controls on the cloud infrastructure. This control ensures that MessageSafe takes responsibility for securing the personal data that it processes on behalf of A&M LLP on the cloud platform provided by Cloud Inc. According to the GDPR, data processors must implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of processing personal data1 These measures may include encryption, pseudonymisation, access control, backup and recovery, logging and monitoring, vulnerability management, incident response, etc2 Furthermore, data processors must ensure that any sub-processors they engage to process personal data on behalf of the data controller also comply with the same obligations3 Therefore, MessageSafe must ensure that Cloud Inc. provides adequate security guarantees for the cloud infrastructure and services that it uses to host the email continuity service for A&M LLP. MessageSafe must also monitor and audit the security performance of Cloud Inc. and report any issues or breaches to A&M LLP. References: 1: Article 32 GDPR | General Data Protection Regulation (GDPR); 2: Guidelines 4/2019 on Article 25 Data Protection by Design and by Default | European Data Protection Board; 3: Article 28 GDPR | General Data Protection Regulation (GDPR)
NEW QUESTION # 92
Under the General Data Protection Regulation (GDPR), what are the obligations of a processor that engages a sub-processor?
Answer: D
Explanation:
Under the General Data Protection Regulation (GDPR), the obligations of a processor that engages a sub-processor are to obtain the consent of the controller and ensure the sub-processor complies with data processing obligations that are equivalent to those that apply to the processor. The GDPR defines a processor as a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller. A sub-processor is a third party that is engaged by the processor to carry out specific processing activities on behalf of the controller. The GDPR requires that the processor does not engage another processor without prior specific or general written authorization of the controller. In the case of general written authorization, the processor must inform the controller of any intended changes concerning the addition or replacement of other processors, thereby giving the controller the opportunity to object to such changes. The processor must also ensure that the same data protection obligations as set out in the contract or other legal act between the controller and the processor are imposed on that other processor by way of a contract or other legal act under Union or Member State law, . Reference: [GDPR Article 28], [CIPM - International Association of Privacy Professionals]
NEW QUESTION # 93
SCENARIO
Please use the following to answer the next question:
Paul Daniels, with years of experience as a CEO, is worried about his son Carlton's successful venture, Gadgo.
A technological innovator in the communication industry that quickly became profitable, Gadgo has moved beyond its startup phase. While it has retained its vibrant energy, Paul fears that under Carlton's direction, the company may not be taking its risks or obligations as seriously as it needs to. Paul has hired you, a privacy Consultant, to assess the company and report to both father and son. "Carlton won't listen to me," Paul says,
"but he may pay attention to an expert."
Gadgo's workplace is a clubhouse for innovation, with games, toys, snacks, espresso machines, giant fish tanks and even an iguana who regards you with little interest. Carlton, too, seems bored as he describes to you the company's procedures and technologies for data protection. It's a loose assemblage of controls, lacking consistency and with plenty of weaknesses. "This is a technology company," Carlton says. "We create. We innovate. I don't want unnecessary measures that will only slow people down and clutter their thoughts." The meeting lasts until early evening. Upon leaving, you walk through the office. It looks as if a strong windstorm has recently blown through, with papers scattered across desks and tables and even the floor. A
"cleaning crew" of one teenager is emptying the trash bins. A few computers have been left on for the night; others are missing. Carlton takes note of your attention to this: "Most of my people take their laptops home with them, or use their own tablets or phones. I want them to use whatever helps them to think and be ready day or night for that great insight. It may only come once!" What would be the best kind of audit to recommend for Gadgo?
Answer: C
NEW QUESTION # 94
Which of the following controls does the PCI DSS framework NOT require?
Answer: C
Explanation:
The PCI DSS framework does not require implementing strong asset control protocols. Asset control protocols are policies and procedures that govern how an organization manages its physical and digital assets, such as inventory, equipment, software, data, etc. Asset control protocols may include aspects such as identification, classification, valuation, tracking, maintenance, disposal, etc. Asset control protocols are important for ensuring the security and integrity of an organization's assets, but they are not part of the PCI DSS framework.
NEW QUESTION # 95
......
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