Released IAPP CIPM Updated Questions PDF
CIPM Dumps and Practice Test (182 Exam Questions)
NEW QUESTION # 62
SCENARIO
Please use the following to answer the next QUESTION:
Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new privacy officer. The company is based in California but thanks to some great publicity from a social media influencer last year, the company has received an influx of sales from the EU and has set up a regional office in Ireland to support this expansion. To become familiar with Ace Space's practices and assess what her privacy priorities will be, Penny has set up meetings with a number of colleagues to hear about the work that they have been doing and their compliance efforts.
Penny's colleague in Marketing is excited by the new sales and the company's plans, but is also concerned that Penny may curtail some of the growth opportunities he has planned. He tells her "I heard someone in the breakroom talking about some new privacy laws but I really don't think it affects us. We're just a small company. I mean we just sell accessories online, so what's the real risk?" He has also told her that he works with a number of small companies that help him get projects completed in a hurry. "We've got to meet our deadlines otherwise we lose money. I just sign the contracts and get Jim in finance to push through the payment. Reviewing the contracts takes time that we just don't have." In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken a number of precautions to protect its website from malicious activity, it has not taken the same level of care of its physical files or internal infrastructure. Penny's colleague in IT has told her that a former employee lost an encrypted USB key with financial data on it when he left. The company nearly lost access to their customer database last year after they fell victim to a phishing attack. Penny is told by her IT colleague that the IT team
"didn't know what to do or who should do what. We hadn't been trained on it but we're a small team though, so it worked out OK in the end." Penny is concerned that these issues will compromise Ace Space's privacy and data protection.
Penny is aware that the company has solid plans to grow its international sales and will be working closely with the CEO to give the organization a data "shake up". Her mission is to cultivate a strong privacy culture within the company.
Penny has a meeting with Ace Space's CEO today and has been asked to give her first impressions and an overview of her next steps.
To help Penny and her CEO with their objectives, what would be the most helpful approach to address her IT concerns?
- A. Undertake a tabletop exercise
- B. Roll out an encryption policy
- C. Host a town hall discussion for all IT employees
- D. Ensure inventory of IT assets is maintained
Answer: A
Explanation:
Explanation
The most helpful approach to address Penny's IT concerns is to undertake a tabletop exercise. A tabletop exercise is a simulated scenario that tests the organization's ability to respond to a security incident, such as a data breach, a cyberattack, or a malware infection. A tabletop exercise typically involves:
* A facilitator who guides the participants through the scenario and injects additional challenges or variables
* A scenario that describes a plausible security incident based on real-world threats or past incidents
* A set of objectives that define the expected outcomes and goals of the exercise
* A set of questions that prompt the participants to discuss their roles, responsibilities, actions, decisions, and communications during the incident response process
* A feedback mechanism that collects the participants' opinions and suggestions on how to improve the incident response plan and capabilities A tabletop exercise can help Penny and her CEO with their objectives by:
* Enhancing the awareness and skills of the IT team and other stakeholders involved in incident response
* Identifying and addressing the gaps, weaknesses, and challenges in the incident response plan and process
* Improving the coordination and collaboration among the IT team and other stakeholders during incident response
* Evaluating and validating the effectiveness and efficiency of the incident response plan and process
* Generating and implementing lessons learned and best practices for incident response
NEW QUESTION # 63
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 a TRUE statement about the relationship among the organizations?
- A. MessageSafe is liable if Cloud Inc. fails to protect data from A&M LLP.
- B. Cloud Inc. must notify A&M LLP of a data breach immediately.
- C. A&M LLP's service contract must be amended to list Cloud Inc. as a sub-processor.
- D. Cloud Inc. should enter into a data processor agreement with A&M LLP.
Answer: A
Explanation:
Explanation
A true statement about the relationship among the organizations is that MessageSafe is liable if Cloud Inc.
fails to protect data from A&M LLP. This statement reflects the principle of accountability under the GDPR, which requires data controllers and processors to be responsible for complying with the GDPR and demonstrating their compliance4 As a data processor for A&M LLP, MessageSafe is liable for any damage caused by processing that infringes the GDPR or by processing that does not comply with A&M LLP's lawful instructions5 This liability extends to any sub-processors that MessageSafe engages to carry out specific processing activities on behalf of A&M LLP5 Therefore, if Cloud Inc., as a sub-processor for MessageSafe, fails to protect data from A&M LLP and causes harm to the data subjects or breaches the GDPR or A&M LLP's instructions, MessageSafe will be held liable for such failure and may have to pay compensation or face administrative fines or other sanctions6 References: 4: Article 5 GDPR | General Data Protection Regulation (GDPR); 5: Article 82 GDPR | General Data Protection Regulation (GDPR); 6: Article 83 GDPR | General Data Protection Regulation (GDPR)
NEW QUESTION # 64
What does it mean to "rationalize" data protection requirements?
- A. Look for overlaps in laws and regulations from which a common solution can be developed
- B. Evaluate the costs and risks of applicable laws and regulations and address those that have the greatest penalties
- C. Determine where laws and regulations are redundant in order to eliminate some from requiring compliance
- D. Address the less stringent laws and regulations, and inform stakeholders why they are applicable
Answer: C
NEW QUESTION # 65
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 process could most effectively be used to add privacy protections to a new, comprehensive program being developed at Consolidated?
- A. Information Security Planning.
- B. Privacy Step Assessment.
- C. Privacy by Design.
- D. Innovation Privacy Standards.
Answer: C
Explanation:
Explanation
This is a process that embeds privacy protections into the design and development of new technologies, systems, products or services that involve personal data. It ensures that privacy is considered at every stage of the development process, from conception to completion, and that the privacy principles are integrated into the core functionality of the program.
NEW QUESTION # 66
What are you doing if you succumb to "overgeneralization" when analyzing data from metrics?
- A. Trying to use several measurements to gauge one aspect of a program
- B. Using data that is too broad to capture specific meanings
- C. Using limited data in an attempt to support broad conclusions
- D. Possessing too many types of data to perform a valid analysis
Answer: B
NEW QUESTION # 67
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 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?
- A. An external audit conducted by a panel of industry experts
- B. Creation of a self-certification framework based on company policies
- C. An internal audit team accountable to upper management
- D. Revision of the strategic plan to provide a system of technical controls
Answer: D
NEW QUESTION # 68
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.
Based on the scenario, what additional change will increase the effectiveness of the privacy compliance hotline?
- A. Strict communication channels.
- B. A system for staff education.
- C. An ethics complaint department.
- D. Outsourcing the hotline.
Answer: B
Explanation:
Explanation
Based on the scenario, an additional change that will increase the effectiveness of the privacy compliance hotline is a system for staff education. A privacy compliance hotline is a mechanism for employees, customers, or other stakeholders to report any concerns or violations of the company's privacy policy or applicable laws. However, a hotline alone is not sufficient to ensure a robust and compliant privacy program.
Employees also need to be educated and trained on the importance of privacy, the company's privacy policy and procedures, their roles and responsibilities, and the consequences of non-compliance. A system for staff education can help raise awareness, foster a culture of privacy, and prevent or mitigate potential risks. References: [Privacy Compliance Hotline], [Staff Education]
NEW QUESTION # 69
What is one reason the European Union has enacted more comprehensive privacy laws than the United States?
- A. To allow separate industries to set privacy standards
- B. To allow the free movement of data between member countries
- C. To ensure there is adequate funding for enforcement
- D. To ensure adequate enforcement of existing laws
Answer: B
NEW QUESTION # 70
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 Eurek a. 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 can Sanjay do to minimize the risks of offering the product in Europe?
- A. Sanjay should work with Manasa to review and remediate the Handy Helper as a gating item before it is released.
- B. Sanjay should document the data life cycle of the data collected by the Handy Helper.
- C. Sanjay should write a privacy policy to include with the Handy Helper user guide.
- D. Sanjay should advise the distributor that Omnipresent Omnimedia has certified to the Privacy Shield Framework and there should be no issues.
Answer: B
NEW QUESTION # 71
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 elements of the incident did you adequately determine?
- A. The nature of the data elements impacted
- B. The likelihood the incident may lead to harm
- C. The number of individuals whose information was affected
- D. The likelihood that the information is accessible and usable
Answer: B
NEW QUESTION # 72
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?
- A. Failure to obtain opt-in consent to marketing.
- B. Failure to integrate privacy throughout the system development life cycle.
- C. Failure to observe data localization requirements.
- D. Failure to implement the least privilege access standard.
Answer: C
NEW QUESTION # 73
Which statement is FALSE regarding the use of technical security controls?
- A. A person with security knowledge should be involved with the deployment of technical security controls.
- B. Technical security controls are part of a data governance strategy.
- C. Technical security controls deployed for one jurisdiction often satisfy another jurisdiction.
- D. Most privacy legislation lists the types of technical security controls that must be implemented.
Answer: C
NEW QUESTION # 74
Which of the documents below assists the Privacy Manager in identifying and responding to a request from an individual about what personal information the organization holds about then with whom the information is shared?
- A. Personal information inventory
- B. Privacy policy
- C. Records retention schedule
- D. Risk register
Answer: A
Explanation:
Explanation
A personal information inventory is a document that assists the Privacy Manager in identifying and responding to a request from an individual about what personal information the organization holds about them and with whom the information is shared. A personal information inventory is a comprehensive and detailed record of all personal information that an organization collects, uses, discloses, stores, and disposes of. It helps an organization map its data flows, assess its privacy risks, comply with its legal obligations, and respond to data subject requests. A personal information inventory should include information such as: the categories and sources of personal information; the purposes and legal bases for processing; the recipients and transfers of personal information; the retention periods and disposal methods; and the security measures and safeguards.
References:
* CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section B:
Protecting Personal Information, Subsection 3: Data Inventory
* CIPM Study Guide (2021), Chapter 8: Protecting Personal Information, Section 8.3: Data Inventory
* CIPM Textbook (2019), Chapter 8: Protecting Personal Information, Section 8.3: Data Inventory
* CIPM Practice Exam (2021), Question 138
NEW QUESTION # 75
How do privacy audits differ from privacy assessments?
- A. They are based on standards.
- B. They are non-binding.
- C. They are evidence-based.
- D. They are conducted by external parties.
Answer: C
Explanation:
Explanation
Privacy audits differ from privacy assessments in that they are evidence-based, meaning that they rely on objective and verifiable data to evaluate the compliance and effectiveness of the privacy program. Privacy assessments, on the other hand, are based on standards, meaning that they use a set of criteria or best practices to measure the performance and maturity of the privacy program. Privacy audits are usually conducted by external parties, while privacy assessments can be done internally or externally. References: CIPM Body of Knowledge, Domain III: Privacy Program Operational Life Cycle, Section A: Assess, Subsection 1: Privacy Assessments and Audits.
NEW QUESTION # 76
SCENARIO
Please use the following to answer the next question:
Edufox has hosted an annual convention of users of its famous e-learning software platform, and over time, it has become a grand event. It fills one of the large downtown conference hotels and overflows into the others, with several thousand attendees enjoying three days of presentations, panel discussions and networking. The convention is the centerpiece of the company's product rollout schedule and a great training opportunity for current users. The sales force also encourages prospective clients to attend to get a better sense of the ways in which the system can be customized to meet diverse needs and understand that when they buy into this system, they are joining a community that feels like family.
This year's conference is only three weeks away, and you have just heard news of a new initiative supporting it:
a smartphone app for attendees. The app will support late registration, highlight the featured presentations and provide a mobile version of the conference program. It also links to a restaurant reservation system with the best cuisine in the areas featured. "It's going to be great," the developer, Deidre Hoffman, tells you, "if, that is, we actually get it working!" She laughs nervously but explains that because of the tight time frame she'd been given to build the app, she outsourced the job to a local firm. "It's just three young people," she says, "but they do great work." She describes some of the other apps they have built. When asked how they were selected for this job, Deidre shrugs. "They do good work, so I chose them." Deidre is a terrific employee with a strong track record. That's why she's been charged to deliver this rushed project. You're sure she has the best interests of the company at heart, and you don't doubt that she's under pressure to meet a deadline that cannot be pushed back. However, you have concerns about the app's handling of personal data and its security safeguards. Over lunch in the break room, you start to talk to her about it, but she quickly tries to reassure you, "I'm sure with your help we can fix any security issues if we have to, but I doubt there'll be any. These people build apps for a living, and they know what they're doing. You worry too much, but that's why you're so good at your job!" You see evidence that company employees routinely circumvent the privacy officer in developing new initiatives. How can you best draw attention to the scope of this problem?
- A. Take your concerns straight to the Chief Executive Officer.
- B. Hold discussions with the department head of anyone who fails to consult with the privacy officer.
- C. Develop a metric showing the number of initiatives launched without consultation and include it in reports, presentations, and consultation.
- D. Insist upon one-on-one consultation with each person who works around the privacy officer.
Answer: B
NEW QUESTION # 77
SCENARIO
Please use the following to answer the next QUESTION:
Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new privacy officer. The company is based in California but thanks to some great publicity from a social media influencer last year, the company has received an influx of sales from the EU and has set up a regional office in Ireland to support this expansion. To become familiar with Ace Space's practices and assess what her privacy priorities will be, Penny has set up meetings with a number of colleagues to hear about the work that they have been doing and their compliance efforts.
Penny's colleague in Marketing is excited by the new sales and the company's plans, but is also concerned that Penny may curtail some of the growth opportunities he has planned. He tells her "I heard someone in the breakroom talking about some new privacy laws but I really don't think it affects us. We're just a small company. I mean we just sell accessories online, so what's the real risk?" He has also told her that he works with a number of small companies that help him get projects completed in a hurry. "We've got to meet our deadlines otherwise we lose money. I just sign the contracts and get Jim in finance to push through the payment. Reviewing the contracts takes time that we just don't have." In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken a number of precautions to protect its website from malicious activity, it has not taken the same level of care of its physical files or internal infrastructure. Penny's colleague in IT has told her that a former employee lost an encrypted USB key with financial data on it when he left. The company nearly lost access to their customer database last year after they fell victim to a phishing attack. Penny is told by her IT colleague that the IT team "didn't know what to do or who should do what. We hadn't been trained on it but we're a small team though, so it worked out OK in the end." Penny is concerned that these issues will compromise Ace Space's privacy and data protection.
Penny is aware that the company has solid plans to grow its international sales and will be working closely with the CEO to give the organization a data "shake up". Her mission is to cultivate a strong privacy culture within the company.
Penny has a meeting with Ace Space's CEO today and has been asked to give her first impressions and an overview of her next steps.
To help Penny and her CEO with their objectives, what would be the most helpful approach to address her IT concerns?
- A. Host a town hall discussion for all IT employees
- B. Undertake a tabletop exercise
- C. Roll out an encryption policy
- D. Ensure inventory of IT assets is maintained
Answer: C
NEW QUESTION # 78
When building a data privacy program, what is a good starting point to understand the scope of privacy program needs?
- A. Perform Risk Assessments
- B. Complete a Data Inventory.
- C. Perform Data Protection Impact Assessments (DPIAs).
- D. Review Audits.
Answer: B
Explanation:
Explanation
A data inventory is a good starting point to understand the scope of privacy program needs, as it provides a comprehensive overview of what personal data is collected, processed, stored, shared, and disposed of by the organization. A data inventory can help identify the legal obligations, risks, and gaps in the privacy program, as well as the opportunities for improvement and optimization. The other options are also important components of a privacy program, but they are more effective when based on a data inventory. References: CIPM Body of Knowledge, Domain II: Privacy Program Operational Life Cycle, Task
1: Assess the current state of the privacy program.
NEW QUESTION # 79
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?
- A. Confidentiality Breach.
- B. Authenticity Breach.
- C. Integrity Breach.
- D. Availability Breach.
Answer: A
Explanation:
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
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