IAPP CIPM Certified Information Privacy Manager (CIPM) Exam Practice Test

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Total 262 questions

Certified Information Privacy Manager (CIPM) Questions and Answers

Question 1

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 NOT an obligation of MessageSafe as the email continuity service provider for A&M LLP?

Options:

Privacy compliance.

Security commitment.

Certifications to relevant frameworks.

Data breach notification to A&M LLP.

Question 2

Which of the following practices best ensures the continuous assessment of program performance within the operational life cycle?

Options:

Completing third-party audits by subject matter experts.

Prioritizing ongoing improvement efforts.

Evaluating emerging risks every 24 months.

Allocating training costs in favor of the privacy and security teams.

Question 3

You are the privacy officer at a university. Recently, the police have contacted you as they suspect that one of your students is using a library computer to commit financial fraud. The police would like your assistance in investigating this individual and are requesting computer logs and usage data of the student.

What Is your first step in responding to the request?

Options:

Refuse the request as the police do not have a warrant.

Provide the data to police and record it for your own archives.

Contact the university's legal counsel to determine if the request is lawful.

Review policies, procedures and legislation to determine the university's obligation to co-operate with the police.

Question 4

Under the European Data Protection Board (EDPB). which processing operation would require a DPIA?

Options:

An online newspaper using its subscriber list to email a daily newsletter.

A healthcare clinic that processes personal data of its patients in its billing system.

A hospital processing patient's genetic and health data in its hospital information system.

An online store displaying advertisements based on items viewed or purchased on its own website.

Question 5

SCENARIO

Please use the following to answer the next QUESTION:

Natalia, CFO of the Nationwide Grill restaurant chain, had never seen her fellow executives so anxious. Last week, a data processing firm used by the company reported that its system may have been hacked, and customer data such as names, addresses, and birthdays may have been compromised. Although the attempt was proven unsuccessful, the scare has prompted several Nationwide Grill executives to Question the company's privacy program at today's meeting.

Alice, a vice president, said that the incident could have opened the door to lawsuits, potentially damaging

Nationwide Grill's market position. The Chief Information Officer (CIO), Brendan, tried to assure her that even if there had been an actual breach, the chances of a successful suit against the company were slim. But Alice remained unconvinced.

Spencer – a former CEO and currently a senior advisor – said that he had always warned against the use of contractors for data processing. At the very least, he argued, they should be held contractually liable for telling customers about any security incidents. In his view, Nationwide Grill should not be forced to soil the company name for a problem it did not cause.

One of the business development (BD) executives, Haley, then spoke, imploring everyone to see reason. "Breaches can happen, despite organizations' best efforts," she remarked. "Reasonable preparedness is key." She reminded everyone of the incident seven years ago when the large grocery chain Tinkerton's had its financial information compromised after a large order of Nationwide Grill frozen dinners. As a long-time BD executive with a solid understanding of Tinkerton's's corporate culture, built up through many years of cultivating relationships, Haley was able to successfully manage the company's incident response.

Spencer replied that acting with reason means allowing security to be handled by the security functions within the company – not BD staff. In a similar way, he said, Human Resources (HR) needs to do a better job training employees to prevent incidents. He pointed out that Nationwide Grill employees are overwhelmed with posters, emails, and memos from both HR and the ethics department related to the company's privacy program. Both the volume and the duplication of information means that it is often ignored altogether.

Spencer said, "The company needs to dedicate itself to its privacy program and set regular in-person trainings for all staff once a month."

Alice responded that the suggestion, while well-meaning, is not practical. With many locations, local HR departments need to have flexibility with their training schedules. Silently, Natalia agreed.

What is the most realistic step the organization can take to help diminish liability in the event of another incident?

Options:

Requiring the vendor to perform periodic internal audits.

Specifying mandatory data protection practices in vendor contracts.

Keeping the majority of processing activities within the organization.

Obtaining customer consent for any third-party processing of personal data.

Question 6

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 data. 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.

In consideration of the company’s new initiatives, which of the following laws and regulations would be most

appropriate for Albert to mention at the interview as a priority concern for the privacy team?

Options:

Gramm-Leach-Bliley Act (GLBA)

The General Data Protection Regulation (GDPR)

The Telephone Consumer Protection Act (TCPA)

Health Insurance Portability and Accountability Act (HIPAA)

Answer:

Explanation:

The most appropriate law for Albert to mention at the interview as a priority concern for the privacy team is the Health Insurance Portability and Accountability Act (HIPAA). HIPAA is a US federal law that establishes national standards for the protection of sensitive patient health information. HIPAA regulates the use, disclosure, and safeguarding of protected health information (PHI), which is any information that can identify a patient or relate to their health or health care services. HIPAA applies to covered entities, such as health plans, health care providers, and health care clearinghouses, and their business associates, such as vendors, contractors, or partners that access or handle PHI on their behalf. HIPAA requires covered entities and business associates to comply with the Privacy Rule, which sets forth the rights of individuals and the obligations of entities regarding PHI; the Security Rule, which specifies the administrative, technical, and physical safeguards to ensure the confidentiality, integrity, and availability of PHI; and the Breach Notification Rule, which requires the notification of individuals, HHS, and in some cases the media, in the event of a breach of unsecured PHI.

Since Treasure Box intends to acquire a medical supply company in the coming weeks, it is likely that it will become a business associate of some covered entities under HIPAA. Therefore, it will need to ensure that its privacy program is compliant with HIPAA requirements and that it has appropriate agreements and safeguards in place to protect PHI. Albert should mention this as a priority concern for the privacy team and demonstrate his awareness and knowledge of HIPAA.

The other options are not as relevant or important as HIPAA for Treasure Box’s new initiatives. The Gramm-Leach-Bliley Act (GLBA) is a US federal law that requires financial institutions to explain how they share and protect their customers’ non-public personal information. It also repealed the Glass-Steagall Act of 1933, which prohibited commercial banks from offering investment and insurance services. GLBA does not apply to Treasure Box since it is not a financial institution. The General Data Protection Regulation (GDPR) is an EU law that provides a comprehensive framework for the protection of personal data of individuals in the EU. It imposes strict obligations and rights on data controllers and processors regarding the collection, use, disclosure, and security of personal data. GDPR does not apply to Treasure Box since it has recently decided to limit its shipments to customers in the 48 contiguous states of the US. The Telephone Consumer Protection Act (TCPA) is a US federal law that restricts telemarketing calls, text messages, faxes, and prerecorded messages. It requires prior express consent from consumers before making such communications and provides consumers with the right to opt out or revoke their consent. TCPA may apply to Treasure Box since it engages in direct phone marketing, but it is not a new initiative or a priority concern for the privacy team. References: HIPAA; GLBA; GDPR; [TCPA]

Question 7

What is the name for the privacy strategy model that describes delegated decision making?

Options:

De-centralized.

De-functionalized.

Hybrid.

Matrix.

Question 8

SCENARIO

Please use the following lo answer the next question:

You are the privacy manager within the privacy office of a National Forest Parks and Recreation Department. While having lunch with a colleague from the IT division, you learn that the IT director has put out a request for proposal (RFP) which calls for a system that collects the personal data of park attendees.

You consult with a few other colleagues in IT and learn that the RFP is worded such that it leaves it to the vendors to demonstrate what information they would collect from people who enter parks anywhere in the country, either in a vehicle or on foot. A partial list of the information collected includes:

• personal identifiers such as name, address, age, gender;

• vehicle registration information:

• facial images of park attendees;

• health information (e.g.. physical disabilities, use of mobility devices)

The stated purpose of the RFP is to:

"Improve the National Forest. Parks, and Recreation Department's ability to track and monitor service usage thereby Increasing the robustness of our customer data and to improve service offerings.''

Companies have already started submitting proposals for software solutions that address these information gathering practices. There is only one week left before the RFP closes.

The IT department has put together an RFP evaluation team but no one from the privacy office has been a Dart of the RFP ud to this point. This occurred deposite the fact….

Which of the following data protection actions has been implemented by the National Forest Parks and Recreation Department?

Options:

Policy creation.

Data minimization.

Sufficient engagement with the privacy team.

Identification of all of the sources, types and uses of personal information(PI).

Question 9

(A business resiliency metric measures an organization's ability to?)

Options:

Reform policies after negative audit outcomes.

Gain new business through privacy initiatives.

Maintain continuous operations during crises.

Adhere to changes in privacy legislation.

Question 10

Which of the following best supports implementing controls to bring privacy policies into effect?

Options:

The internal audit department establishing the audit controls which test for policy effectiveness.

The legal department or outside counsel conducting a thorough review of the privacy program and policies.

The Chief Information Officer as part of the Senior Management Team creating enterprise privacy policies to ensure controls are available.

The information technology (IT) group supporting and enhancing the privacy program and privacy policy by developing processes and controls.

Question 11

In regards to the collection of personal data conducted by an organization, what must the data subject be allowed to do?

Options:

Evaluate the qualifications of a third-party processor before any data is transferred to that processor.

Obtain a guarantee of prompt notification in instances involving unauthorized access of the data.

Set a time-limit as to how long the personal data may be stored by the organization.

Challenge the authenticity of the personal data and have it corrected if needed.

Question 12

SCENARIO

Please use the following to answer the next QUESTION:

Martin Briseño is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseño 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 Briseño 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 Briseño’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. Briseño 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?

Options:

As the parent company, it should have transferred personnel to oversee the secure handling of PHT’s data.

As the parent company, it should have performed an assessment of PHT’s infrastructure and confirmed complete separation of the two networks.

As the parent company, it should have ensured its existing data access and storage procedures were integrated into PHT’s system.

As the parent company, it should have replaced PHT’s electronic files with hard-copy documents stored securely on site.

Question 13

Which of the following is NOT a type of privacy program metric?

Options:

Business enablement metrics.

Data enhancement metrics.

Value creation metrics.

Risk-reduction metrics.

Question 14

All of the following are accurate regarding the use of technical security controls EXCEPT?

Options:

Technical security controls are part of a data governance strategy.

Technical security controls deployed for one jurisdiction often satisfy another jurisdiction.

Most privacy legislation lists the types of technical security controls that must be implemented.

A person with security knowledge should be involved with the deployment of technical security controls.

Question 15

MULTI-SELECT – Select 3

A multinational manufacturing company is considering outsourcing its HR data processing to a third-party vendor based in a country with less strict data protection laws. The company has a large database of employee information, including personal and sensitive data such as national ID numbers, medical information and employment contracts. The third-party vendor has a reputation for providing cost-effective services and has assured the company that it can handle the data securely.

The data protection officer (DPO) should ensure which of the following contractual requirements are included in the agreement with the third-party vendor?

Options:

How a breach would be handled.

How the vendor is insured.

How data transfers take place.

How appropriate security will be maintained.

How the cost of doing business will be reduced.

Question 16

Which of the following is a physical control that can limit privacy risk?

Options:

Keypad or biometric access.

user access reviews.

Encryption.

Tokenization.

Question 17

Integrating privacy requirements into functional areas across the organization happens at which stage of the privacy operational life cycle?

Options:

Assessing data.

Protecting personal data.

Sustaining program performance.

Responding to requests and incidents.

Question 18

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?

Options:

Add security cameras at facilities that are now without them.

Set policies about the purpose and use of the security cameras.

Reduce the number of security cameras located inside the building.

Restrict access to surveillance video taken by the security cameras and destroy the recordings after a designated period of time.

Question 19

Which of the following helps build trust with customers and stakeholders?

Options:

Only publish what is legally necessary to reduce your liability.

Enable customers to view and change their own personal information within a dedicated portal.

Publish your privacy policy using broad language to ensure all of your organization’s activities are captured.

Provide a dedicated privacy space with the privacy policy, explanatory documents and operation frameworks.

Question 20

Which of the following is NOT a main technical data control area?

Options:

Obfuscation.

Tokenization.

Access controls.

Data minimization.

Question 21

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 data. 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.

In terms of compliance with regulatory and legislative changes, Anton has a misconception regarding?

Options:

The timeline for monitoring.

The method of recordkeeping.

The use of internal employees.

The type of required qualifications.

Question 22

(All of the following are components of a data collection notice EXCEPT?)

Options:

The categories of information shared with third parties.

The length of time the personal information will be stored.

The meta-data which could be generated from collection of the information.

The lawful interests pursued by the responsible party collecting the information.

Question 23

There are different forms of monitoring available for organizations to consider when aligning with their privacy program goals.

Which of the following forms of monitoring is best described as ‘auditing’?

Options:

Evaluating operations, systems, and processes.

Tracking, reporting and documenting complaints from all sources.

Assisting in the completion of attesting reporting for SOC2, ISO, or BS7799.

Ensuring third parties have appropriate security and privacy requirements in place.

Question 24

The first step an organization should take when considering the use of a third-party's AI-based resume ranking tool is to?

Options:

Secure stakeholder buy-in and approval to ensure the tool meets the organization's requirements.

Conduct an assessment of the tool's impact both on privacy and on conformity with applicable AI regulation.

Distribute a notice to the candidates whose resumes the tool will assess to ensure they understand and consent to the use of the tool.

Secure appropriate contractual concessions to ensure that the developer is primarily responsible for any violation of applicable privacy law.

Question 25

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 stage of the privacy operational life cycle best describes Consolidated's current privacy program?

Options:

Assess.

Protect.

Respond.

Sustain.

Question 26

Which of the following is the most likely way an independent privacy organization might work to promote sound privacy practices?

Options:

By developing principles for self-regulation.

By enacting new legislation.

By completing on-site audits.

By issuing penalties for violations of rules.

Question 27

An online retailer detects an incident involving customer shopping history but no keys have been compromised. The Privacy Offce is most concerned when it also involves?

Options:

Internal unique personal identifiers.

Plain text personal identifiers.

Hashed mobile identifiers.

No personal identifiers.

Question 28

Which will best assist you in quickly identifying weaknesses in your network and storage?

Options:

Running vulnerability scanning tools.

Reviewing your privacy program metrics.

Reviewing your role-based access controls.

Establishing a complaint-monitoring process.

Question 29

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 Eureka. 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 element of the Privacy by Design (PbD) framework might the Handy Helper violate?

Options:

Failure to obtain opt-in consent to marketing.

Failure to observe data localization requirements.

Failure to implement the least privilege access standard.

Failure to integrate privacy throughout the system development life cycle.

Question 30

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.

In order to determine the best course of action, how should this incident most productively be viewed?

Options:

As the accidental loss of personal property containing data that must be restored.

As a potential compromise of personal information through unauthorized access.

As an incident that requires the abrupt initiation of a notification campaign.

As the premeditated theft of company data, until shown otherwise.

Question 31

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?

Options:

First-party audit.

Second-party audit.

Third-party audit.

Fourth-party audit.

Answer:

Explanation:

A third-party audit would help an organization achieve the objective of demonstrating compliance with international privacy standards and identifying gaps for remediation. A third-party audit is an audit conducted by an independent and external auditor who is not affiliated with either the audited organization or its customers. A third-party audit can provide an objective and impartial assessment of the organization’s privacy practices and policies, as well as verify its compliance with relevant standards and regulations. A third-party audit can also help the organization identify areas for improvement and recommend corrective actions. A third-party audit can enhance the organization’s reputation, trustworthiness, and credibility among its stakeholders and customers.

A first-party audit is an audit conducted by the organization itself or by someone within the organization who has been designated as an auditor. A first-party audit is also known as an internal audit. A first-party audit can help the organization monitor its own performance, evaluate its compliance with internal policies and procedures, and identify potential risks and opportunities for improvement. However, a first-party audit may not be sufficient to demonstrate compliance with external standards and regulations, as it may lack independence and objectivity.

A second-party audit is an audit conducted by a party that has an interest in or a relationship with the audited organization, such as a customer, a supplier, or a partner. A second-party audit is also known as an external audit. A second-party audit can help the party verify that the audited organization meets its contractual obligations, expectations, and requirements. A second-party audit can also help the party evaluate the quality and reliability of the audited organization’s products or services. However, a second-party audit may not be able to provide a comprehensive and unbiased assessment of the audited organization’s privacy practices and policies, as it may be influenced by the party’s own interests and objectives. References: Types of Audits: 14 Types of Audits and Level of Assurance (2022)

Question 32

Which of the following is TRUE about the Data Protection Impact Assessment (DPIA) process as required under the General Data Protection Regulation (GDPR)?

Options:

The DPIA result must be reported to the corresponding supervisory authority.

The DPIA report must be published to demonstrate the transparency of the data processing.

The DPIA must include a description of the proposed processing operation and its purpose.

The DPIA is required if the processing activity entails risk to the rights and freedoms of an EU individual.

Question 33

SCENARIO

Please use the following to answer the next QUESTION:

With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the job.

Based on Albert’s observations, executive leadership should most likely pay closer attention to what?

Options:

Awareness campaigns with confusing information

Obsolete data processing systems

Outdated security frameworks

Potential in-house threats

Question 34

SCENARIO

Please use the following to answer the next QUESTION:

Richard McAdams recently graduated law school and decided to return to the small town of Lexington, Virginia to help run his aging grandfather's law practice. The elder McAdams desired a limited, lighter role in the practice, with the hope that his grandson would eventually take over when he fully retires. In addition to hiring Richard, Mr. McAdams employs two paralegals, an administrative assistant, and a part-time IT specialist who handles all of their basic networking needs. He plans to hire more employees once Richard gets settled and assesses the office's strategies for growth.

Immediately upon arrival, Richard was amazed at the amount of work that needed to done in order to modernize the office, mostly in regard to the handling of clients' personal data. His first goal is to digitize all the records kept in file cabinets, as many of the documents contain personally identifiable financial and medical data. Also, Richard has noticed the massive amount of copying by the administrative assistant throughout the day, a practice that not only adds daily to the number of files in the file cabinets, but may create security issues unless a formal policy is firmly in place Richard is also concerned with the overuse of the communal copier/ printer located in plain view of clients who frequent the building. Yet another area of concern is the use of the same fax machine by all of the employees. Richard hopes to reduce its use dramatically in order to ensure that personal data receives the utmost security and protection, and eventually move toward a strict Internet faxing policy by the year's end.

Richard expressed his concerns to his grandfather, who agreed, that updating data storage, data security, and an overall approach to increasing the protection of personal data in all facets is necessary Mr. McAdams granted him the freedom and authority to do so. Now Richard is not only beginning a career as an attorney, but also functioning as the privacy officer of the small firm. Richard plans to meet with the IT employee the following day, to get insight into how the office computer system is currently set-up and managed.

Which of the following policy statements needs additional instructions in order to further protect the personal data of their clients?

Options:

All faxes sent from the office must be documented and the phone number used must be double checked to ensure a safe arrival.

All unused copies, prints, and faxes must be discarded in a designated recycling bin located near the work station and emptied daily.

Before any copiers, printers, or fax machines are replaced or resold, the hard drives of these devices must be deleted before leaving the office.

When sending a print job containing personal data, the user must not leave the information visible on the computer screen following the print command and must retrieve the printed document immediately.

Question 35

What should be the first major goal of a company developing a new privacy program?

Options:

To survey potential funding sources for privacy team resources.

To schedule conversations with executives of affected departments.

To identify potential third-party processors of the organization's information.

To create Data Lifecycle Management policies and procedures to limit data collection.

Question 36

Under which circumstances would people who work in human resources be considered a secondary audience for privacy metrics?

Options:

They do not receive training on privacy issues

They do not interface with the financial office

They do not have privacy policy as their main task

They do not have frequent interactions with the public

Question 37

SCENARIO

Please use the following to answer the next QUESTION:

Ben works in the IT department of IgNight, Inc., a company that designs lighting solutions for its clients. Although IgNight's customer base consists primarily of offices in the US, some individuals have been so impressed by the unique aesthetic and energy-saving design of the light fixtures that they have requested IgNight's installations in their homes across the globe.

One Sunday morning, while using his work laptop to purchase tickets for an upcoming music festival, Ben happens to notice some unusual user activity on company files. From a cursory review, all the data still appears to be where it is meant to be but he can't shake off the feeling that something is not right. He knows that it is a possibility that this could be a colleague performing unscheduled maintenance, but he recalls an email from his company's security team reminding employees to be on alert for attacks from a known group of malicious actors specifically targeting the industry.

Ben is a diligent employee and wants to make sure that he protects the company but he does not want to bother his hard-working colleagues on the weekend. He is going to discuss the matter with this manager first thing in the morning but wants to be prepared so he can demonstrate his knowledge in this area and plead his case for a promotion.

If this were a data breach, how is it likely to be categorized?

Options:

Availability Breach.

Authenticity Breach.

Confidentiality Breach.

Integrity Breach.

Answer:

Explanation:

If this were a data breach, it is likely to be categorized as a confidentiality breach. A confidentiality breach is a type of data breach that involves unauthorized or accidental disclosure of or access to personal data. A confidentiality breach violates the principle of confidentiality, which requires that personal data is protected from unauthorized or unlawful use or disclosure. A confidentiality breach can occur when personal data is exposed to unauthorized parties, such as hackers, competitors, or third parties without consent. A confidentiality breach can also occur when personal data is sent to incorrect recipients, such as by email or mail.

The other options are not likely to be the correct category for this data breach. An availability breach is a type of data breach that involves accidental or unauthorized loss of access to or destruction of personal data. An availability breach violates the principle of availability, which requires that personal data is accessible and usable by authorized parties when needed. An availability breach can occur when personal data is deleted, corrupted, encrypted, or otherwise rendered inaccessible by malicious actors or technical errors. An authenticity breach is a type of data breach that involves unauthorized or accidental alteration of personal data. An authenticity breach violates the principle of authenticity, which requires that personal data is accurate and up to date. An authenticity breach can occur when personal data is modified, tampered with, or falsified by malicious actors or human errors. An integrity breach is a type of data breach that involves unauthorized or accidental alteration of personal data that affects its quality or reliability. An integrity breach violates the principle of integrity, which requires that personal data is complete and consistent with its intended purpose. An integrity breach can occur when personal data is incomplete, inconsistent, outdated, or inaccurate due to malicious actors or human errors. References: Personal Data Breaches: A Guide; Guidance on the Categorisation and Notification of Personal Data Breaches

Question 38

SCENARIO

Please use the following to answer the next question

You were recently hired by InStyte Date Corp as a privacy manager to help InStyle Data Corp become compliant with a new data protection law

The law mandates that businesses have reasonable and appropriate security measures in place to protect personal data. Violations of that mandate are heavily fined and the legislators have stated that they will aggressively pursue companies that don t comply with the new law

You are paved with a security manager and tasked with reviewing InStyle Data Corp s current state and advising the business how it can meet the "reasonable and appropriate security" requirement InStyle Data Corp has grown rapidly and has not kept a data inventory or completed a data mapping InStyte Data Corp has also developed security-related policies ad hoc and many have never been implemented The various teams involved in the creation and testing of InStyle Data Corp s products experience significant turnover and do not have well defined roles There's little documentation addressing what personal data is processed by which product and for what purpose

Work needs to begin on this project immediately so that InStyle Data Corp can become compliant by the time the law goes into effect. You and you partner discover that InStyle Data Corp regularly sends files containing sensitive personal data back to its customers through email sometimes using InStyle Data Corp employees personal email accounts. You also team that InStyle Data Corp s privacy and information security teams are not informed of new personal data flows, new products developed by InStyte Data Corp that process personal data, or updates to existing InStyle Data Corp products that may change what or how the personal data is processed until after the product or update has gone have.

Through a review of InStyle Date Corp’s test and development environment logs, you discover InStyle Data Corp sometimes gives login credentials to any InStyle Data Corp employee or contractor who requests them. The test environment only contains dummy data but the development environment contains personal data including Social Security Numbers, hearth ^formation and financial information All credentialed InStyle Data Corp employees and contractors have the ability to after and delete personal data in both environments regardless of their role or what project they are working on.

You and your partner provide a gap assessment citing the issues you spotted, along with recommended remedial actions and a method to measure implementation InStyle Data Corp implements all of the recommended security controls You review the processes roles, controls and measures taken to appropriately protect the personal data at every stop However, you realize there is no plan for monitoring and nothing in place addressing sanctions for violations of the updated policies and procedures InStyle Data Corp pushes back, stating they do not have the resources for such monitoring.

Having completed the gap assessment, you and your partner need to first undertake a thorough review of?

Options:

Data life cyde

Security policies.

System development life cycle.

Privacy Impact (PIA).

Question 39

Which statement is FALSE regarding the use of technical security controls?

Options:

Technical security controls are part of a data governance strategy.

Technical security controls deployed for one jurisdiction often satisfy another jurisdiction.

Most privacy legislation lists the types of technical security controls that must be implemented.

A person with security knowledge should be involved with the deployment of technical security controls.

Question 40

SCENARIO

Please use the following lo answer the next question:

The board risk committee of your organization is particularly concerned not only by the number and frequency of data breaches reported to it over the past 12 months, but also the inconsistency in responses and poor incident response turnaround times.

Upon reviewing the current incident response plan (IRP), it was discovered that while the business continuity plan (BCP> had been updated on time, the IRP, linked to BCP. was last updated over three years ago.

The board risk committee has noted this as high risk especially since company policy is to review and update policies and plans annually. Consequently, the newly appointed data protection officer (DPO) was requested to provide a paper on how she would remediate the situation.

As a seasoned data privacy professional, you have been requested to assist the new DPO.

Your first recommendation in addressing the board risk committee's concerns is to?

Options:

Integrate the IRP into the BCP so it is not a stand-alone document.

Conduct a table-top exercise based on the version of the IRP that is currently on record.

Focus on training and awareness sessions in order to familiarize relevant staff with current policies and procedures.

Update the IRP with the applicable emergency contact information, policies and procedures, as well as timelines and action steps.

Question 41

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 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 analytic can be used to track the financial viability of the program as it develops?

Options:

Cost basis.

Gap analysis.

Return to investment.

Breach impact modeling.

Question 42

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.

The company has achieved a level of privacy protection that established new best practices for the industry. What is a logical next step to help ensure a high level of protection?

Options:

Brainstorm methods for developing an enhanced privacy framework

Develop a strong marketing strategy to communicate the company’s privacy practices

Focus on improving the incident response plan in preparation for any breaks in protection

Shift attention to privacy for emerging technologies as the company begins to use them

Question 43

According to the General Data Protection Regulation (GDPR), the requirements of a Data Protection Impact Assessment (DPIA) include that it?

Options:

Be reported to the corresponding supervisory authority.

Publish the report to demonstrate the transparency of the data processing.

Provide a description of the proposed processing operation and its purpose.

Is required if the processing activity entails risk to the rights and freedoms of an EU individual.

Question 44

The purpose of a data flow map is to help an organization do all of the following EXCEPT?

Options:

Determine unidentified opportunities for information collection.

Assist compliance with privacy-related laws and regulations.

Identify any.

Recognize who in the organization has access to what information.

Question 45

If your organization has a recurring issue with colleagues not reporting personal data breaches, all of the following are advisable to do EXCEPT?

Options:

Review reporting activity on breaches to understand when incidents are being reported and when they are not to improve communication and training.

Improve communication to reinforce to everyone that breaches must be reported and how they should be reported.

Provide role-specific training to areas where breaches are happening so they are more aware.

Distribute a phishing exercise to all employees to test their ability to recognize a threat attempt.

Question 46

Post-liquidation, a company that has acquired assets would require separate consent from a data subject if personally identifiable data were being retained for which purpose?

Options:

For tax purposes.

For analytical purposes.

To be able to ensure payment of pension funds.

To secure employment benefits for former employees.

Question 47

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?

Options:

Report the theft to law enforcement

Wipe the hard drive remotely

Report the theft to the senior management

Perform a multi-factor risk analysis

Question 48

A marketing team regularly exports spreadsheets to use (or analysis including customer name, birthdate and home address. These spreadsheets are routinely shared between members of various teams via email even with employees that do not need such granular data.

What is the best way to lower overall risk?

Options:

Set up security measures in the company's email client to prevent spreadsheets with customer information from accidentally being sent to external recipients.

Anonymize exportable data by creating categories of information, like age range and geographic region.

Allow the free exchange of information to continue but require spreadsheets be password protected.

Allow only certain users to export customer data from the database.

Question 49

Privacy/security questionnaires are used primarily to do what?

Options:

Map data flows.

Assess vendor risk.

Determine access controls.

Comply with contractual requirements.

Question 50

SCENARIO

Please use the following to answer the next QUESTION:

Amira is thrilled about the sudden expansion of NatGen. As the joint Chief Executive Officer (CEO) with her long-time business partner Sadie, Amira has watched the company grow into a major competitor in the green energy market. The current line of products includes wind turbines, solar energy panels, and equipment for geothermal systems. A talented team of developers means that NatGen's line of products will only continue to grow.

With the expansion, Amira and Sadie have received advice from new senior staff members brought on to help manage the company's growth. One recent suggestion has been to combine the legal and security functions of the company to ensure observance of privacy laws and the company's own privacy policy. This sounds overly complicated to Amira, who wants departments to be able to use, collect, store, and dispose of customer data in ways that will best suit their needs. She does not want administrative oversight and complex structuring to get in the way of people doing innovative work.

Sadie has a similar outlook. The new Chief Information Officer (CIO) has proposed what Sadie believes is an unnecessarily long timetable for designing a new privacy program. She has assured him that NatGen will use the best possible equipment for electronic storage of customer and employee data. She simply needs a list of equipment and an estimate of its cost. But the CIO insists that many issues are necessary to consider before the company gets to that stage.

Regardless, Sadie and Amira insist on giving employees space to do their jobs. Both CEOs want to entrust the monitoring of employee policy compliance to low-level managers. Amira and Sadie believe these managers can adjust the company privacy policy according to what works best for their particular departments. NatGen's CEOs know that flexible interpretations of the privacy policy in the name of promoting green energy would be highly unlikely to raise any concerns with their customer base, as long as the data is always used in course of normal business activities.

Perhaps what has been most perplexing to Sadie and Amira has been the CIO's recommendation to institute a

privacy compliance hotline. Sadie and Amira have relented on this point, but they hope to compromise by allowing employees to take turns handling reports of privacy policy violations. The implementation will be easy because the employees need no special preparation. They will simply have to document any concerns they hear.

Sadie and Amira are aware that it will be challenging to stay true to their principles and guard against corporate culture strangling creativity and employee morale. They hope that all senior staff will see the benefit of trying a unique approach.

What is the most likely reason the Chief Information Officer (CIO) believes that generating a list of needed IT equipment is NOT adequate?

Options:

The company needs to have policies and procedures in place to guide the purchasing decisions.

The privacy notice for customers and the Business Continuity Plan (BCP) still need to be reviewed.

Staff members across departments need time to review technical information concerning any new databases.

Senior staff members need to first commit to adopting a minimum number of Privacy Enhancing Technologies (PETs).

Question 51

SCENARIO

Please use the following lo answer the next question:

• personal identifiers such as name, address, age, gender;

• vehicle registration information:

• facial images of park attendees;

• health information (e.g.. physical disabilities, use of mobility devices)

The stated purpose of the RFP is to:

"Improve the National Forest. Parks, and Recreation Department's ability to track and monitor service usage thereby Increasing the robustness of our customer data and to improve service offerings.''

Companies have already started submitting proposals for software solutions that address these information gathering practices. There is only one week left before the RFP closes.

The IT department has put together an RFP evaluation team but no one from the privacy office has been a Dart of the RFP ud to this point. This occurred deposite the fact….

All of the following are appropriate for the privacy office in developing a privacy assessment metric EXCEPT?

Options:

Clarifying what data fields are to be collected, including use cases for all purposes.

Canceling this RFP and re-issuing it after thorough consultation with your office.

Obtaining a list of vendors and the services they are offering in response to the RFP requirements.

Extending the deadline for the RFP giving your office more time to assess the privacy needs of the program.

Question 52

PbD is the framework that?

Options:

Dictates the design of the system development life cycle.

Establishes risk-based expectations for privacy management.

Embeds privacy into the design of technology, systems and practices.

Guides organizations in designing, implementing and managing privacy programs in line with privacy laws and best practices.

Question 53

What should a privacy professional keep in mind when selecting which metrics to collect?

Options:

Metrics should be reported to the public.

The number of metrics should be limited at first.

Metrics should reveal strategies for increasing company earnings.

A variety of metrics should be collected before determining their specific functions.

Question 54

A new business crafting its privacy policy is struggling with how it will define the term "personal data."

Which of the following should inform this decision?

Options:

The types of special categories of data being processed.

The business's requirements for storing collected data.

The amount of data the business expects to collect.

The privacy laws to which the business is subject.

Question 55

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.

Which of the following was done CORRECTLY during the above incident?

Options:

The process by which affected individuals sign up for email notifications

Your assessment of which credit monitoring company you should hire

The speed at which you sat down to reflect and document the incident

Finding a vendor who will offer the affected individuals additional services

Question 56

Which of the following indicates you have developed the right privacy framework for your organization?

Options:

It includes a privacy assessment of each major system.

It improves the consistency of the privacy program.

It works at a different type of organization.

It identifies all key stakeholders by name.

Question 57

When implementing Privacy by Design (PbD), what would NOT be a key consideration?

Options:

Collection limitation.

Data minimization.

Limitations on liability.

Purpose specification.

Question 58

What is the function of the privacy operational life cycle?

Options:

It establishes initial plans for privacy protection and implementation

It allows the organization to respond to ever-changing privacy demands

It ensures that outdated privacy policies are retired on a set schedule

It allows privacy policies to mature to a fixed form

Question 59

SCENARIO

Please use the following to answer the next QUESTION:

What key mistake set the company up to be vulnerable to a security breach?

Options:

Collecting too much information and keeping it for too long

Overlooking the need to organize and categorize data

Failing to outsource training and data management to professionals

Neglecting to make a backup copy of archived electronic files

Question 60

Which of the following actions is NOT required during a data privacy diligence process for Merger & Acquisition (M&A) deals?

Options:

Revise inventory of applications that house personal data and data mapping.

Update business processes to handle Data Subject Requests (DSRs).

Compare the original use of personal data to post-merger use.

Perform a privacy readiness assessment before the deal.

Question 61

Which of the following is NOT an important factor to consider when developing a data retention policy?

Options:

Technology resource.

Business requirement.

Organizational culture.

Compliance requirement

Question 62

What is the main function of the Asia-Pacific Economic Cooperation Privacy Framework?

Options:

Enabling regional data transfers.

Protecting data from parties outside the region.

Establishing legal requirements for privacy protection in the region.

Marketing privacy protection technologies developed in the region.

Question 63

What is the key factor that lays the foundation for all other elements of a privacy program?

Options:

The applicable privacy regulations

The structure of a privacy team

A privacy mission statement

A responsible internal stakeholder

Question 64

(From a privacy perspective, what is the first concern organizations must tackle when considering using a third-party AI tool to screen job applications?)

Options:

Analyzing compliance with privacy laws and AI regulations.

Preparing a notice for job applicants in advance of tool deployment.

Assigning contractual responsibility in case of regulatory non-compliance.

Identifying the most suitable vendor based on organizational requirements.

Question 65

Creating a privacy governance model for an organization that is required to appoint data protection officers under the GDPR poses what additional challenge?

Options:

They must react without delay to suppliers.

They must reply personally to data subjects.

They must report directly to top management.

They must respond immediately to employees.

Question 66

SCENARIO

Please use the following to answer the next QUESTION:

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.

The CEO likes what he’s seen of the company’s improved privacy program, but wants additional assurance that it is fully compliant with industry standards and reflects emerging best practices. What would best help accomplish this goal?

Options:

An external audit conducted by a panel of industry experts

An internal audit team accountable to upper management

Creation of a self-certification framework based on company policies

Revision of the strategic plan to provide a system of technical controls

Question 67

SCENARIO

Please use the following to answer the next QUESTION:

With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the job.

What is one important factor that Albert fails to consider regarding Treasure Box’s response to their recent security incident?

Options:

Who has access to the data

What the nature of the data is

How data at the company is collected

How long data at the company is kept

Question 68

The main reason the response to this incident should be integrated into the Business Continuity Plan (BCP) is because?

Options:

The repercussions for the company could have significant environmental impacts.

The need for retraining employees will be paramount.

Major stakeholders are involved from every critical area of the business.

The impact on the company's competitive advantage is potentially significant.

Question 69

Which of the following is NOT a type of privacy program metric?

Options:

Business enablement metrics.

Data enhancement metrics.

Value creation metrics.

Commercial metrics.

Question 70

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!"

Which is the best first step in understanding the data security practices of a potential vendor?

Options:

Requiring the vendor to complete a questionnaire assessing International Organization for Standardization (ISO) 27001 compliance.

Conducting a physical audit of the vendor's facilities.

Conducting a penetration test of the vendor's data security structure.

Examining investigation records of any breaches the vendor has experienced.

Question 71

What United States federal law requires financial institutions to declare their personal data collection practices?

Options:

The Kennedy-Hatch Disclosure Act of 1997.

The Gramm-Leach-Bliley Act of 1999.

SUPCLA, or the federal Superprivacy Act of 2001.

The Financial Portability and Accountability Act of 2006.

Question 72

When implementing an organization's privacy program, what right should be granted to the data subject?

Options:

To have their data amended or erased if errors are found.

To limit or refuse the disclosure of their data for any reason.

To provide feedback regarding an organization's privacy policy.

To verify that an organization uses the highest level of privacy protection available.

Question 73

How do privacy audits differ from privacy assessments?

Options:

They are non-binding.

They are evidence-based.

They are based on standards.

They are conducted by external parties.

Question 74

All of the following would address your concern of the copy room EXCEPT?

Options:

Placing a paper shredder in the copy room.

Initiating a PIA.

Hanging a poster reminding users to shred paper.

Implementing a new paper record destruction policy.

Question 75

In addition to regulatory requirements and business practices, what important factors must a global privacy strategy consider?

Options:

Monetary exchange.

Geographic features.

Political history.

Cultural norms.

Question 76

Which of the following controls are generally NOT part of a PIA review?

Options:

Access.

Incident.

Retention.

Collection.

Question 77

Which of the following methods analyzes data collected based the scale and not the endpoint of the privacy program?

Options:

Trend Analysis.

Business Resiliency.

Return on Investment.

The Privacy Maturity Model.

Question 78

(Which law is applicable to the customer's right to opt out?)

Options:

CPRA.

GDPR.

EU-U.S. DPF.

PIPEDA.

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IAPP CIPM Certified Information Privacy Manager (CIPM) Exam Practice Test

Certified Information Privacy Manager (CIPM) Questions and Answers

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