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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Operational Life Cycle of a Privacy Program | 50% | - Managing data inventory and data flows - Implementing privacy controls and procedures - Monitoring, auditing, and continuous improvement - Assessing privacy risks and impacts |
| Topic 2: Privacy Program Governance | 50% | - Policy development and implementation - Stakeholder engagement and communication - Privacy program structure and governance models - Metrics, reporting, and accountability |
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NEW QUESTION # 251
According to the General Data Protection Regulation (GDPR), the requirements of a Data Protection Impact Assessment (DPIA) include that it?
Answer: C
Explanation:
Comprehensive and Detailed Explanation:
A Data Protection Impact Assessment (DPIA) is required under Article 35 of the GDPR and must include a description of the proposed processing operation and its purpose to assess risks to data subjects.
* Option A (Reported to the supervisory authority) - DPIAs are generally not reported automatically unless the risks cannot be mitigated.
* Option B (Publishing the report for transparency) - While organizations should be transparent, GDPR does not require public publication of DPIAs.
* Option D (Required if the activity entails risk to individuals' rights and freedoms) - This is true, but it is a condition for conducting a DPIA, not a specific requirement of the DPIA itself.
* Option C (Provide a description of the proposed processing operation and its purpose) is the correct answer because Article 35 of GDPR explicitly requires this information in the DPIA.
Reference:GDPR Article 35 (DPIA Requirements) - CIPM Official Textbook, Module: Privacy Impact Assessments and Risk Management.
NEW QUESTION # 252
A minimum requirement for carrying out a Data Protection Impact Assessment (DPIA) would include?
Answer: A
Explanation:
Processing on a large scale of special categories of data is a minimum requirement for carrying out a Data Protection Impact Assessment (DPIA) under the General Data Protection Regulation (GDPR). A DPIA is a type of Privacy Impact Assessment (PIA) that is specifically required by the GDPR when a processing activity is likely to result in a high risk to the rights and freedoms of natural persons. According to Article 35 (3)(b) of the GDPR, a DPIA is mandatory when the processing involves a large scale of special categories of data or personal data relating to criminal convictions and offences. Special categories of data are personal data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life or sexual orientation. These types of data are considered more sensitive and require more protection, as they may pose higher risks of discrimination, identity theft, fraud, or other harms to the data subjects.
References:
CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section C:
Monitoring and Managing Program Performance Subsection 1: Privacy Impact Assessments CIPM Study Guide (2021), Chapter 9: Monitoring and Managing Program Performance Section 9.1: Privacy Impact Assessments CIPM Textbook (2019), Chapter 9: Monitoring and Managing Program Performance Section 9.1: Privacy Impact Assessments CIPM Practice Exam (2021), Question 147 GDPR Article 35(3)(b) and Article 9
NEW QUESTION # 253
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: C
NEW QUESTION # 254
What have experts identified as an important trend in privacy program development?
Answer: D
NEW QUESTION # 255
SCENARIO
Please use the following to answer the next QUESTION:
You lead the privacy office for a company that handles information from individuals living in several countries throughout Europe and the Americas. You begin that morning's privacy review when a contracts officer sends you a message asking for a phone call. The message lacks clarity and detail, but you presume that data was lost.
When you contact the contracts officer, he tells you that he received a letter in the mail from a vendor stating that the vendor improperly shared information about your customers. He called the vendor and confirmed that your company recently surveyed exactly 2000 individuals about their most recent healthcare experience and sent those surveys to the vendor to transcribe it into a database, but the vendor forgot to encrypt the database as promised in the contract. As a result, the vendor has lost control of the data.
The vendor is extremely apologetic and offers to take responsibility for sending out the notifications. They tell you they set aside 2000 stamped postcards because that should reduce the time it takes to get the notice in the mail. One side is limited to their logo, but the other side is blank and they will accept whatever you want to write. You put their offer on hold and begin to develop the text around the space constraints. You are content to let the vendor's logo be associated with the notification.
The notification explains that your company recently hired a vendor to store information about their most recent experience at St. Sebastian Hospital's Clinic for Infectious Diseases. The vendor did not encrypt the information and no longer has control of it. All 2000 affected individuals are invited to sign-up for email notifications about their information. They simply need to go to your company's website and watch a quick advertisement, then provide their name, email address, and month and year of birth.
You email the incident-response council for their buy-in before 9 a.m. If anything goes wrong in this situation, you want to diffuse the blame across your colleagues. Over the next eight hours, everyone emails their comments back and forth. The consultant who leads the incident-response team notes that it is his first day with the company, but he has been in other industries for 45 years and will do his best. One of the three lawyers on the council causes the conversation to veer off course, but it eventually gets back on track. At the end of the day, they vote to proceed with the notification you wrote and use the vendor's postcards.
Shortly after the vendor mails the postcards, you learn the data was on a server that was stolen, and make the decision to have your company offer credit monitoring services. A quick internet search finds a credit monitoring company with a convincing name: Credit Under Lock and Key (CRUDLOK). Your sales rep has never handled a contract for 2000 people, but develops a proposal in about a day which says CRUDLOK will:
1.Send an enrollment invitation to everyone the day after the contract is signed.
2.Enroll someone with just their first name and the last-4 of their national identifier.
3.Monitor each enrollee's credit for two years from the date of enrollment.
4.Send a monthly email with their credit rating and offers for credit-related services at market rates.
5.Charge your company 20% of the cost of any credit restoration.
You execute the contract and the enrollment invitations are emailed to the 2000 individuals. Three days later you sit down and document all that went well and all that could have gone better. You put it in a file to reference the next time an incident occurs.
Regarding the credit monitoring, which of the following would be the greatest concern?
Answer: C
Explanation:
This answer is the greatest concern regarding the credit monitoring, as it may compromise the accuracy and effectiveness of the service, as well as expose the affected individuals to further privacy and security risks.
The company did not collect enough identifiers to monitor one's credit means that the company only asked for the first name and the last-4 of their national identifier from the enrollees, which may not be sufficient or unique to identify and verify their identity and credit history. This may lead to errors, disputes or inaccuracies in the credit monitoring service, as well as potential identity theft, fraud or misuse of the data by unauthorized or malicious parties.
NEW QUESTION # 256
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