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NEW QUESTION # 76
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 administrative safeguards should be implemented to protect the collected data while in use by Manasa and her product management team?
- A. Document the data flows for the collected data.
- B. Implement a policy restricting data access on a "need to know" basis.
- C. Limit data transfers to the US by keeping data collected in Europe within a local data center.
- D. Conduct a Privacy Impact Assessment (PIA) to evaluate the risks involved.
Answer: B
Explanation:
An administrative safeguard that should be implemented to protect the collected data while in use by Manasa and her product management team is a policy restricting data access on a "need to know" basis. This means that only authorized personnel who have a legitimate business purpose for accessing the data should be able to do so3 This would help to prevent unauthorized or unnecessary access, use, or disclosure of sensitive or personal data by internal or external parties. It would also reduce the risk of data breaches, theft, or loss that could compromise the confidentiality, integrity, and availability of the data4 Reference: 3: HIPAA Security Series #2 - Administrative Safeguards - HHS.gov; 4: Administrative Safeguards of the Security Rule: What Are They?
NEW QUESTION # 77
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'?
- A. Tracking, reporting and documenting complaints from all sources.
- B. Evaluating operations, systems, and processes.
- C. Assisting in the completion of attesting reporting for SOC2, ISO, or BS7799.
- D. Ensuring third parties have appropriate security and privacy requirements in place.
Answer: B
Explanation:
Explanation
Evaluating operations, systems, and processes is best described as 'auditing', as it involves conducting a systematic and independent examination of the organization's privacy practices and controls to verify their effectiveness and compliance. The other options are more related to other forms of monitoring, such as complaint handling, reporting, and third-party oversight. References: CIPM Body of Knowledge, Domain III:
Privacy Program Management Activities, Task 5: Monitor privacy program performance.
NEW QUESTION # 78
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. Privacy Step Assessment
- B. Innovation Privacy Standards
- C. Information Security Planning
- D. Privacy by Design
Answer: C
NEW QUESTION # 79
SCENARIO
Please use the following to answer the next question:
You lead the privacy office for a company that handles information from individuals living in several countries throughout Europe and the Americas. You begin that morning's privacy review when a contracts officer sends you a message asking for a phone call. The message lacks clarity and detail, but you presume that data was lost.
When you contact the contracts officer, he tells you that he received a letter in the mail from a vendor stating that the vendor improperly shared information about your customers. He called the vendor and confirmed that your company recently surveyed exactly 2000 individuals about their most recent healthcare experience and sent those surveys to the vendor to transcribe it into a database, but the vendor forgot to encrypt the database as promised in the contract. As a result, the vendor has lost control of the data.
The vendor is extremely apologetic and offers to take responsibility for sending out the notifications. They tell you they set aside 2000 stamped postcards because that should reduce the time it takes to get the notice in the mail. One side is limited to their logo, but the other side is blank and they will accept whatever you want to write. You put their offer on hold and begin to develop the text around the space constraints. You are content to let the vendor's logo be associated with the notification.
The notification explains that your company recently hired a vendor to store information about their most recent experience at St. Sebastian Hospital's Clinic for Infectious Diseases. The vendor did not encrypt the information and no longer has control of it. All 2000 affected individuals are invited to sign-up for email notifications about their information. They simply need to go to your company's website and watch a quick advertisement, then provide their name, email address, and month and year of birth.
You email the incident-response council for their buy-in before 9 a.m. If anything goes wrong in this situation, you want to diffuse the blame across your colleagues. Over the next eight hours, everyone emails their comments back and forth. The consultant who leads the incident-response team notes that it is his first day with the company, but he has been in other industries for 45 years and will do his best. One of the three lawyers on the council causes the conversation to veer off course, but it eventually gets back on track. At the end of the day, they vote to proceed with the notification you wrote and use the vendor's postcards.
Shortly after the vendor mails the postcards, you learn the data was on a server that was stolen, and make the decision to have your company offer credit monitoring services. A quick internet search finds a credit monitoring company with a convincing name: Credit Under Lock and Key (CRUDLOK). Your sales rep has never handled a contract for 2000 people, but develops a proposal in about a day which says CRUDLOK will:
1.Send an enrollment invitation to everyone the day after the contract is signed.
2.Enroll someone with just their first name and the last-4 of their national identifier.
3.Monitor each enrollee's credit for two years from the date of enrollment.
4.Send a monthly email with their credit rating and offers for credit-related services at market rates.
5.Charge your company 20% of the cost of any credit restoration.
You execute the contract and the enrollment invitations are emailed to the 2000 individuals. Three days later you sit down and document all that went well and all that could have gone better. You put it in a file to reference the next time an incident occurs.
Regarding the credit monitoring, which of the following would be the greatest concern?
- A. Signing a contract with CRUDLOK which lasts longer than one year
- B. You are going to notify affected individuals via a letter followed by an email
- C. The vendor's representative does not have enough experience
- D. The company did not collect enough identifiers to monitor one's credit
Answer: C
NEW QUESTION # 80
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.
Based on Albert's observations regarding recent security incidents, which of the following should he suggest as a priority for Treasure Box?
- A. Using a third-party auditor to address privacy protection issues not recognized by the prior internal audits.
- B. Appointing an internal ombudsman to address employee complaints regarding hours and pay.
- C. Evaluating the company's ability to handle personal health information if the plan to acquire the medical supply company goes forward
- D. Working with the Human Resources department to make screening procedures for potential employees more rigorous.
Answer: C
NEW QUESTION # 81
When building a data privacy program, what is a good starting point to understand the scope of privacy program needs?
- A. Perform Data Protection Impact Assessments (DPIAs).
- B. Review Audits.
- C. Perform Risk Assessments
- D. Complete a Data Inventory.
Answer: D
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 # 82
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.
How could the objection to Spencer's training suggestion be addressed?
- A. By customizing training based on length of employee tenure.
- B. By introducing a system of periodic refresher trainings.
- C. By offering alternative delivery methods for trainings.
- D. By requiring training only on an as-needed basis.
Answer: C
NEW QUESTION # 83
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 dat a. 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.
Richard believes that a transition from the use of fax machine to Internet faxing provides all of the following security benefits EXCEPT?
- A. The ability to encrypt the transmitted faxes through a secure server.
- B. Greater accessibility to the faxes at an off-site location.
- C. Reduction of the risk of data being seen or copied by unauthorized personnel.
- D. The ability to store faxes electronically, either on the user's PC or a password-protected network server.
Answer: B
Explanation:
A transition from the use of fax machine to Internet faxing does not provide the security benefit of greater accessibility to the faxes at an off-site location. This is because Internet faxing requires a secure internet connection and a compatible device to access the faxes online. If the user is at an off-site location that does not have these requirements, they may not be able to access their faxes. Furthermore, greater accessibility may not necessarily be a security benefit, as it may also increase the risk of unauthorized access or interception by third parties. Therefore, this option is not a security benefit of Internet faxing.
The other options are security benefits of Internet faxing. The ability to encrypt the transmitted faxes through a secure server ensures that the faxes are protected from eavesdropping or tampering during transmission. The reduction of the risk of data being seen or copied by unauthorized personnel eliminates the need for physical security measures such as locks or shredders for fax machines and paper documents. The ability to store faxes electronically, either on the user's PC or a password-protected network server, allows for better control and management of the faxes and reduces the storage space and costs associated with paper documents. Reference: 1: Is Online Fax Secure in 2023? All You Need to Know!; 2: Is faxing secure: How to fax from a computer safely - PandaDoc
NEW QUESTION # 84
How are individual program needs and specific organizational goals identified in privacy framework development?
- A. Through creation of the business case.
- B. Through conversations with the privacy team.
- C. By employing an industry-standard needs analysis.
- D. By employing metrics to align privacy protection with objectives.
Answer: A
Explanation:
Explanation
The creation of the business case is the first step in privacy framework development, as it helps to identify the individual program needs and specific organizational goals. The business case is a document that outlines the rationale, objectives, benefits, costs, risks, and alternatives for implementing a privacy program. It also helps to communicate the value of privacy to stakeholders and gain their support. The other options are subsequent steps in privacy framework development, after the business case has been established. References: CIPM Study Guide, page 15.
NEW QUESTION # 85
If your organization has a recurring issue with colleagues not reporting personal data breaches, all of the following are advisable to do EXCEPT?
- A. Provide role-specific training to areas where breaches are happening so they are more aware.
- B. Improve communication to reinforce to everyone that breaches must be reported and how they should be reported.
- C. Review reporting activity on breaches to understand when incidents are being reported and when they are not to improve communication and training.
- D. Distribute a phishing exercise to all employees to test their ability to recognize a threat attempt.
Answer: D
Explanation:
Distributing a phishing exercise is not advisable when attempting to address the issue of colleagues not reporting personal data breaches. Instead, the recommended steps are to review reporting activity on breaches, improve communication, and provide role-specific training to areas where breaches are happening. These steps will help to ensure that everyone is aware of their responsibilities and that they understand how to report a breach should one occur.
Reference:
https://www.itgovernance.co.uk/blog/5-reasons-why-employees-dont-report-data-breaches/
https://www.ncsc.gov.uk/guidance/report-cyber-incident
https://www.ncsc.gov.uk/guidance/phishing-staff-awareness
NEW QUESTION # 86
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?
- A. Data breach notification to A&M LLP.
- B. Security commitment.
- C. Certifications to relevant frameworks.
- D. Privacy compliance.
Answer: C
NEW QUESTION # 87
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?
- A. Data breach notification to A&M LLP.
- B. Security commitment.
- C. Certifications to relevant frameworks.
- D. Privacy compliance.
Answer: C
NEW QUESTION # 88
SCENARIO
Please use the following to answer the next question:
John is the new privacy officer at the prestigious international law firm - A&M LLP. A&M LLP is very proud of its reputation in the practice areas of Trusts & Estates and Merger & Acquisition in both U.S. and Europe. During lunch with a colleague from the Information Technology department, John heard that the Head of IT, Derrick, is about to outsource the firm's email continuity service to their existing email security vendor - MessageSafe.
Being successful as an email hygiene vendor, MessageSafe is expanding its business by leasing cloud infrastructure from Cloud Inc. to host email continuity service for A&M LLP.
John is very concerned about this initiative. He recalled that MessageSafe was in the news six months ago due to a security breach. Immediately, John did a quick research of MessageSafe's previous breach and learned that the breach was caused by an unintentional mistake by an IT administrator. He scheduled a meeting with Derrick to address his concerns.
At the meeting, Derrick emphasized that email is the primary method for the firm's lawyers to communicate with clients, thus it is critical to have the email continuity service to avoid any possible email downtime. Derrick has been using the anti-spam service provided by MessageSafe for five years and is very happy with the quality of service provided by MessageSafe. In addition to the significant discount offered by MessageSafe, Derrick emphasized that he can also speed up the onboarding process since the firm already has a service contract in place with MessageSafe. The existing on-premises email continuity solution is about to reach its end of life very soon and he doesn't have the time or resource to look for another solution. Furthermore, the off-premises email continuity service will only be turned on when the email service at A&M LLP's primary and secondary data centers are both down, and the email messages stored at MessageSafe site for continuity service will be automatically deleted after 30 days.
Which of the following is the most effective control to enforce MessageSafe's implementation of appropriate technical countermeasures to protect the personal data received from A&M LLP?
- A. MessageSafe must notify A&M LLP of a data breach.
- B. MessageSafe must apply due diligence before trusting Cloud Inc. with the personal data received from A&M LLP.
- C. MessageSafe must flow-down its data protection contract terms with A&M LLP to Cloud Inc.
- D. MessageSafe must apply appropriate security controls on the cloud infrastructure.
Answer: A
NEW QUESTION # 89
Which of the following actions is NOT required during a data privacy diligence process for Merger & Acquisition (M&A) deals?
- A. Update business processes to handle Data Subject Requests (DSRs).
- B. Perform a privacy readiness assessment before the deal.
- C. Compare the original use of personal data to post-merger use.
- D. Revise inventory of applications that house personal data and data mapping.
Answer: B
Explanation:
Explanation
A privacy readiness assessment is not required during a data privacy diligence process for Merger & Acquisition (M&A) deals, as it is usually done before the deal to evaluate the privacy maturity and compliance level of the target organization. The other options are required during the data privacy diligence process to ensure that the personal data of both organizations are handled in accordance with the applicable laws and regulations, as well as the expectations of the data subjects and stakeholders. References: CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 4: Manage data transfers.
NEW QUESTION # 90
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 number of individuals whose information was affected
- B. The likelihood the incident may lead to harm
- C. The nature of the data elements impacted
- D. The likelihood that the information is accessible and usable
Answer: B
NEW QUESTION # 91
SCENARIO
Please use the following to answer the next QUESTION:
It's just what you were afraid of. Without consulting you, the information technology director at your organization launched a new initiative to encourage employees to use personal devices for conducting business. The initiative made purchasing a new, high-specification laptop computer an attractive option, with discounted laptops paid for as a payroll deduction spread over a year of paychecks. The organization is also paying the sales taxes. It's a great deal, and after a month, more than half the organization's employees have signed on and acquired new laptops. Walking through the facility, you see them happily customizing and comparing notes on their new computers, and at the end of the day, most take their laptops with them, potentially carrying personal data to their homes or other unknown locations. It's enough to give you data- protection nightmares, and you've pointed out to the information technology Director and many others in the organization the potential hazards of this new practice, including the inevitability of eventual data loss or theft.
Today you have in your office a representative of the organization's marketing department who shares with you, reluctantly, a story with potentially serious consequences. The night before, straight from work, with laptop in hand, he went to the Bull and Horn Pub to play billiards with his friends. A fine night of sport and socializing began, with the laptop "safely" tucked on a bench, beneath his jacket. Later that night, when it was time to depart, he retrieved the jacket, but the laptop was gone. It was not beneath the bench or on another bench nearby. The waitstaff had not seen it. His friends were not playing a joke on him. After a sleepless night, he confirmed it this morning, stopping by the pub to talk to the cleanup crew. They had not found it. The laptop was missing. Stolen, it seems. He looks at you, embarrassed and upset.
You ask him if the laptop contains any personal data from clients, and, sadly, he nods his head, yes. He believes it contains files on about 100 clients, including names, addresses and governmental identification numbers. He sighs and places his head in his hands in despair.
What should you do first to ascertain additional information about the loss of data?
- A. Call the police to investigate even if you are unsure a crime occurred.
- B. Check company records of the latest backups to see what data may be recoverable.
- C. Investigate the background of the person reporting the incident.
- D. Interview the person reporting the incident following a standard protocol.
Answer: D
NEW QUESTION # 92
When supporting the business and data privacy program expanding into a new jurisdiction, it is important to do all of the following EXCEPT?
- A. Perform an assessment of the laws applicable in that new jurisdiction.
- B. Identify the stakeholders.
- C. Consider culture and whether the privacy framework will need to account for changes in culture.
- D. Appoint a new Privacy Officer (PO) for that jurisdiction.
Answer: D
Explanation:
When expanding into a new jurisdiction, it is not necessary to appoint a new Privacy Officer (PO) for that jurisdiction, unless the local law requires it. The other options are important steps to ensure compliance with the new jurisdiction's privacy laws and regulations, as well as to align the privacy program with the business objectives and culture of the new market. Reference: CIPM Body of Knowledge, Domain I: Privacy Program Governance, Task 1: Establish the privacy program vision and strategy.
NEW QUESTION # 93
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.
What is the best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has?
- A. Analyze the data inventory to map data flows
- B. Audit all vendors' privacy practices and safeguards
- C. Conduct a Privacy Impact Assessment for the company
- D. Review all cloud contracts to identify the location of data servers used
Answer: B
NEW QUESTION # 94
Which of the following is NOT typically a function of a Privacy Officer?
- A. Managing an organization's information security infrastructure.
- B. Serving as an interdepartmental liaison for privacy concerns.
- C. Responding to information access requests from the public.
- D. Monitoring an organization's compliance with privacy laws.
Answer: C
NEW QUESTION # 95
SCENARIO
Please use the following to answer the next QUESTION:
You lead the privacy office for a company that handles information from individuals living in several countries throughout Europe and the Americas. You begin that morning's privacy review when a contracts officer sends you a message asking for a phone call. The message lacks clarity and detail, but you presume that data was lost.
When you contact the contracts officer, he tells you that he received a letter in the mail from a vendor stating that the vendor improperly shared information about your customers. He called the vendor and confirmed that your company recently surveyed exactly 2000 individuals about their most recent healthcare experience and sent those surveys to the vendor to transcribe it into a database, but the vendor forgot to encrypt the database as promised in the contract. As a result, the vendor has lost control of the data.
The vendor is extremely apologetic and offers to take responsibility for sending out the notifications. They tell you they set aside 2000 stamped postcards because that should reduce the time it takes to get the notice in the mail. One side is limited to their logo, but the other side is blank and they will accept whatever you want to write. You put their offer on hold and begin to develop the text around the space constraints. You are content to let the vendor's logo be associated with the notification.
The notification explains that your company recently hired a vendor to store information about their most recent experience at St. Sebastian Hospital's Clinic for Infectious Diseases. The vendor did not encrypt the information and no longer has control of it. All 2000 affected individuals are invited to sign-up for email notifications about their information. They simply need to go to your company's website and watch a quick advertisement, then provide their name, email address, and month and year of birth.
You email the incident-response council for their buy-in before 9 a.m. If anything goes wrong in this situation, you want to diffuse the blame across your colleagues. Over the next eight hours, everyone emails their comments back and forth. The consultant who leads the incident-response team notes that it is his first day with the company, but he has been in other industries for 45 years and will do his best. One of the three lawyers on the council causes the conversation to veer off course, but it eventually gets back on track. At the end of the day, they vote to proceed with the notification you wrote and use the vendor's postcards.
Shortly after the vendor mails the postcards, you learn the data was on a server that was stolen, and make the decision to have your company offer credit monitoring services. A quick internet search finds a credit monitoring company with a convincing name: Credit Under Lock and Key (CRUDLOK). Your sales rep has never handled a contract for 2000 people, but develops a proposal in about a day which says CRUDLOK will:
1. Send an enrollment invitation to everyone the day after the contract is signed.
2. Enroll someone with just their first name and the last-4 of their national identifier.
3. Monitor each enrollee's credit for two years from the date of enrollment.
4. Send a monthly email with their credit rating and offers for credit-related services at market rates.
5. Charge your company 20% of the cost of any credit restoration.
You execute the contract and the enrollment invitations are emailed to the 2000 individuals. Three days later you sit down and document all that went well and all that could have gone better. You put it in a file to reference the next time an incident occurs.
Regarding the credit monitoring, which of the following would be the greatest concern?
- A. Signing a contract with CRUDLOK which lasts longer than one year
- B. You are going to notify affected individuals via a letter followed by an email
- C. The company did not collect enough identifiers to monitor one's credit
- D. The vendor's representative does not have enough experience
Answer: C
Explanation:
This answer is the greatest concern regarding the credit monitoring, as it may compromise the accuracy and effectiveness of the service, as well as expose the affected individuals to further privacy and security risks. The company did not collect enough identifiers to monitor one's credit means that the company only asked for the first name and the last-4 of their national identifier from the enrollees, which may not be sufficient or unique to identify and verify their identity and credit history. This may lead to errors, disputes or inaccuracies in the credit monitoring service, as well as potential identity theft, fraud or misuse of the data by unauthorized or malicious parties.
NEW QUESTION # 96
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 Data Lifecycle Management (DLM) principle should the company follow if they end up allowing departments to interpret the privacy policy differently?
- A. Prove the authenticity of the company's records.
- B. Create categories to reflect degrees of data importance.
- C. Adequately document reasons for inconsistencies.
- D. Arrange for official credentials for staff members.
Answer: C
Explanation:
Explanation
If the company ends up allowing departments to interpret the privacy policy differently, they should follow the Data Lifecycle Management (DLM) principle of adequately documenting reasons for inconsistencies. This principle requires that data should be accurate, complete, and consistent throughout its lifecycle and that any deviations or discrepancies should be justified and recorded1 This would help the company to maintain data quality and integrity, as well as to demonstrate accountability and compliance with data protection regulations2 The other options are not DLM principles that the company should follow if they allow departments to interpret the privacy policy differently. Proving the authenticity of the company's records is a principle related to data preservation and archiving, not data interpretation3 Arranging for official credentials for staff members is a principle related to data access and security, not data interpretation4 Creating categories to reflect degrees of data importance is a principle related to data classification and retention, not data interpretation5 References: 1: Data Lifecycle Management: A Complete Guide | Splunk; 2: Data Lifecycle Management | IBM; 3: Data Preservation | Digital Preservation Handbook; 4: Data Access Management Best Practices | Smartsheet; 5: Data Classification: What It Is And How To Do It | Varonis
NEW QUESTION # 97
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.
Going forward, what is the best way for IgNight to prepare its IT team to manage these kind of security events?
- A. Share communications relating to scheduled maintenance.
- B. Tabletop exercises.
- C. Update its data inventory.
- D. IT security awareness training.
Answer: B
Explanation:
Explanation
The best way for IgNight to prepare its IT team to manage these kind of security events is to conduct tabletop exercises. Tabletop exercises are simulated scenarios that test the organization's ability to respond to security incidents in a realistic and interactive way. Tabletop exercises typically involve:
* 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 Tabletop exercises help an organization prepare for and deal with security incidents 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 The other options are not as effective or useful as tabletop exercises for preparing the IT team to manage security events. Updating the data inventory is a good practice for maintaining an accurate and comprehensive record of the personal data that the organization collects, processes, stores, shares, or disposes of. However, it does not test or improve the organization's incident response capabilities or readiness. IT security awareness training is a good practice for educating the IT team and other employees on the basic principles and practices of cybersecurity. However, it does not simulate or replicate the real-world situations and challenges that the IT team may face during security incidents. Sharing communications relating to scheduled maintenance is a good practice for informing the IT team and other stakeholders of the planned activities and potential impacts on the IT systems and infrastructure. However, it does not prepare the IT team for dealing with unplanned or unexpected security events that may require immediate and coordinated response. References: CISA Tabletop Exercise Packages; Cybersecurity Tabletop Exercise Examples, Best Practices, and Considerations; Six Tabletop Exercises to Help Prepare Your Cybersecurity Team
NEW QUESTION # 98
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