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Total 243 questions

Certified Information Privacy Manager (CIPM) Questions and Answers

Question 1

Your marketing team wants to know why they need a check box for their SMS opt-in. You explain it is part of the consumer's right to?

Options:

A.

Request correction.

B.

Raise complaints.

C.

Have access.

D.

Be informed.

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Question 2

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

Options:

A.

Technical security controls are part of a data governance strategy.

B.

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

C.

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

D.

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

Question 3

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?

Which of the following would be most effectively used as a guide to a systems approach to implementing data protection?

Options:

A.

Data Lifecycle Management Standards.

B.

United Nations Privacy Agency Standards.

C.

International Organization for Standardization 9000 Series.

D.

International Organization for Standardization 27000 Series.

Question 4

Which of the following is TRUE about a PIA (Privacy Impact Analysis)?

Options:

A.

Any project that involves the use of personal data requires a PIA

B.

A Data Protection Impact Analysis (DPIA) process includes a PIA

C.

The PIA must be conducted at the early stages of the project lifecycle

D.

The results from a previous information audit can be leveraged in a PIA process

Question 5

An organization's privacy officer was just notified by the benefits manager that she accidentally sent out the retirement enrollment report of all employees to a wrong vendor.

Which of the following actions should the privacy officer take first?

Options:

A.

Perform a risk of harm analysis.

B.

Report the incident to law enforcement.

C.

Contact the recipient to delete the email.

D.

Send firm-wide email notification to employees.

Question 6

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 can Sanjay do to minimize the risks of offering the product in Europe?

Options:

A.

Sanjay should advise the distributor that Omnipresent Omnimedia has certified to the Privacy Shield Framework and there should be no issues.

B.

Sanjay should work with Manasa to review and remediate the Handy Helper as a gating item before it is released.

C.

Sanjay should document the data life cycle of the data collected by the Handy Helper.

D.

Sanjay should write a privacy policy to include with the Handy Helper user guide.

Question 7

What is the main purpose in notifying data subjects of a data breach?

Options:

A.

To avoid financial penalties and legal liability

B.

To enable regulators to understand trends and developments that may shape the law

C.

To ensure organizations have accountability for the sufficiency of their security measures

D.

To allow i ndividuals to take any actions required to protect the mselves from possible consequences

Question 8

SCENARIO

Please use the following to answer the next question:

Liam is the newly appointed information technology (IT) compliance manager at Mesa, a USbased outdoor clothing brand with a global E-commerce presence. During his second week, he is contacted by the company’s IT audit manager, who informs him that the auditing team will be conducting a review of Mesa’s privacy compliance risk in a month.

A bit nervous about the audit, Liam asks his boss what his predecessor had completed related to privacy compliance before leaving the company. Liam is told that a consent management tool had been added to the website and they commissioned a privacy risk evaluation from a small consulting firm last year that determined that their risk exposure was relatively low given their current control environment. After reading the consultant’s report, Liam realized that the scope of the assessment was limited to breach notification laws in the US and the Payment Card Industry’s Data Security Standard (PCI DSS).

Not wanting to let down his new team, Liam kept his concerns about the report to himself and figured he could try to put some additional controls into place before the audit. Having some privacy compliance experience in his last role, Liam thought he might start by having discussions with the E-commerce and marketing teams.

The E-commerce Director informed him that they were still using the cookie consent tool forcibly placed on the home screen by the CIO, but could not understand the point since their office was not located in California or Europe. The marketing director touted his department’s success with purchasing email lists and taking a shotgun approach to direct marketing. Both directors highlighted their tracking tools on the website to enhance customer experience while learning more about where else the customer had shopped. The more people Liam met with, the more it became apparent that privacy awareness and the general control environment at Mesa needed help.

With three weeks before the audit, Liam updated Mesa's Privacy Notice himself, which was taken and revised from a competitor’s website. He also wrote policies and procedures outlining the roles and responsibilities for privacy within Mesa and distributed the document to all departments he knew of with access to personal information.

During this time. Liam also filled the backlog of data subject requests for deletion that had been sent to him by the customer service manager. Liam worked with application owners to remove these individual's information and order history from the customer relationship management (CRM) tool, the enterprise resource planning (ERP). the data warehouse and the email server.

At the audit kick-off meeting. Liam explained to his boss and her team that there may still be some room for improvement, but he thought the risk had been mitigated to an appropriate level based on the work he had done thus far.

After the audit had been completed, the audit manager and Liam met to discuss her team’s findings, and much to his dismay. Liam was told that none of the work he had completed prior to the audit followed best practices for governance and risk mitigation. In fact, his actions only opened the company up to additional risk and scrutiny. Based on these findings. Liam worked with external counsel and an established privacy consultant to develop a remediation plan.

What key error related to program governance did Liam make prior to the audit kick-off meeting?

Options:

A.

He did not properly escalate his concerns and develop a remediation plan with leadership support.

B.

He met with stakeholders in marketing and E-commerce without the auditors.

C.

He did not conduct a data inventory assessment prior to adopting the policy.

D.

He asked stakeholders to delete customer data out of the CRM tool.

Question 9

“Collection”, “access” and “destruction” are aspects of what privacy management process?

Options:

A.

The data governance strategy

B.

The breach response plan

C.

The metric life cycle

D.

The business case

Question 10

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

Options:

A.

Technical security controls are part of a data governance strategy.

B.

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

C.

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

D.

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

Question 11

SCENARIO

Please use the following lo answer the next question:

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

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

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

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

Which additional proactive step listed below would best mitigate these risks in the future?

Options:

A.

Make the IRP a live document that is evaluated for completeness during each incident.

B.

Make copies of the IRP in various place so it can be accessed remotely or when offline.

C.

Add comments about incidents to the IRP to record what action was taken.

D.

Make sure that everyone listed in the IRP has a copy of the IRP

Question 12

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

Options:

A.

The Kennedy-Hatch Disclosure Act of 1997.

B.

The Gramm-Leach-Bliley Act of 1999.

C.

SUPCLA, or the federal Superprivacy Act of 2001.

D.

The Financial Portability and Accountability Act of 2006.

Question 13

SCENARIO

Please use the following to answer the next QUESTION:

Your organization, the Chicago (U.S.)-based Society for Urban Greenspace, has used the same vendor to operate all aspects of an online store for several years. As a small nonprofit, the Society cannot afford the higher-priced options, but you have been relatively satisfied with this budget vendor, Shopping Cart Saver (SCS). Yes, there have been some issues. Twice, people who purchased items from the store have had their credit card information used fraudulently subsequent to transactions on your site, but in neither case did the investigation reveal with certainty that the Society’s store had been hacked. The thefts could have been employee-related.

Just as disconcerting was an incident where the organization discovered that SCS had sold information it had collected from customers to third parties. However, as Jason Roland, your SCS account representative, points

out, it took only a phone call from you to clarify expectations and the “misunderstanding” has not occurred again.

As an information-technology program manager with the Society, the role of the privacy professional is only one of many you play. In all matters, however, you must consider the financial bottom line. While these problems with privacy protection have been significant, the additional revenues of sales of items such as shirts and coffee cups from the store have been significant. The Society’s operating budget is slim, and all sources of revenue are essential.

Now a new challenge has arisen. Jason called to say that starting in two weeks, the customer data from the store would now be stored on a data cloud. “The good news,” he says, “is that we have found a low-cost provider in Finland, where the data would also be held. So, while there may be a small charge to pass through to you, it won’t be exorbitant, especially considering the advantages of a cloud.”

Lately, you have been hearing about cloud computing and you know it’s fast becoming the new paradigm for various applications. However, you have heard mixed reviews about the potential impacts on privacy protection. You begin to research and discover that a number of the leading cloud service providers have signed a letter of intent to work together on shared conventions and technologies for privacy protection. You make a note to find out if Jason’s Finnish provider is signing on.

What is the best way for your vendor to be clear about the Society’s breach notification expectations?

Options:

A.

Include notification provisions in the vendor contract

B.

Arrange regular telephone check-ins reviewing expectations

C.

Send a memorandum of understanding on breach notification

D.

Email the regulations that require breach notifications

Question 14

Why were the nongovernmental privacy organizations, Electronic Frontier Foundation (EFF) and Electronic Privacy Information Center (EPIC), established?

Options:

A.

To promote consumer confidence in the Internet industry.

B.

To improve the user experience during online shopping.

C.

To protect civil liberties and raise consumer awareness.

D.

To promote security on the Internet through strong encryption.

Question 15

The General Data Protection Regulation (GDPR) specifies fines that may be levied against data controllers for certain infringements. Which of the following will be subject to administrative fines of up to 10 000 000 EUR, or in the case of an undertaking, up to 2% of the total worldwide annual turnover of the preceding financial year?

Options:

A.

Failure to demonstrate that consent was given by the data subject to the processing of their personal data where it is used as the basis for processing

B.

Failure to implement technical and organizational measures to ensure data protection is enshrined by design and default

C.

Failure to process personal information in a manner compatible with its original purpose

D.

Failure to provide the means for a data subject to rectify inaccuracies in personal data

Question 16

SCENARIO

Please use the following to answer the next QUESTION:

Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can be used in the home to manage family calendars, do online shopping, and schedule doctor appointments. After having had a successful launch in the United States, the Handy Helper is about to be made available for purchase worldwide.

The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the whole family, including children, but does not provide any further detail or privacy notice. In order to use the application, a family creates a single account, and the primary user has access to all information about the

other users. Upon start up, the primary user must check a box consenting to receive marketing emails from Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.

Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European distributor of Handy Helper when he fielded many Questions about the product from the distributor. Sanjay needed to look more closely at the product in order to be able to answer the Questions as he was not involved in the product development process.

In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the product. This data is all stored in the cloud and is encrypted both during transmission and at rest.

Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent Omnimedia employees have access to user data under a program called Eureka. Omnipresent Omnimedia is hoping that at some point in the future, the data will reveal insights that could be used to create a fully automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is considered a long-term goal.

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

Options:

A.

Failure to obtain opt-in consent to marketing.

B.

Failure to observe data localization requirements.

C.

Failure to implement the least privilege access standard.

D.

Failure to integrate privacy throughout the system development life cycle.

Question 17

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.

Based on the scenario, Nationwide Grill needs to create better employee awareness of the company's privacy program by doing what?

Options:

A.

Varying the modes of communication.

B.

Communicating to the staff more often.

C.

Improving inter-departmental cooperation.

D.

Requiring acknowledgment of company memos.

Question 18

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

Options:

A.

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

B.

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

C.

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

D.

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

Question 19

Privacy/security questionnaires are used primarily to do what?

Options:

A.

Map data flows.

B.

Assess vendor risk.

C.

Determine access controls.

D.

Comply with contractual requirements.

Question 20

Under the General Data Protection Regulation (GDPR), what must be included in a written agreement between the controller and processor in relation to processing conducted on the controller's behalf?

Options:

A.

An obligation on the processor to report any personal data breach to the controller within 72 hours.

B.

An obligation on both parties to report any serious personal data breach to the supervisory authority.

C.

An obligation on both parties to agree to a termination of the agreement if the other party is responsible for a personal data breach.

D.

An obligation on the processor to assist the controller in complying with the controller's obligations to notify the supervisory authority about personal data breaches.

Question 21

In which situation would a Privacy Impact Assessment (PIA) be the least likely to be required?

Options:

A.

If a company created a credit-scoring platform five years ago.

B.

If a health-care professional or lawyer processed personal data from a patient's file.

C.

If a social media company created a new product compiling personal data to generate user profiles.

D.

If an after-school club processed children's data to determine which children might have food allergies.

Question 22

SCENARIO

Please use the following to answer the next question:

Liam is the newly appointed information technology (IT) compliance manager at Mesa, a USbased outdoor clothing brand with a global E-commerce presence. During his second week, he is contacted by the company’s IT audit manager, who informs him that the auditing team will be conducting a review of Mesa’s privacy compliance risk in a month.

A bit nervous about the audit, Liam asks his boss what his predecessor had completed related to privacy compliance before leaving the company. Liam is told that a consent management tool had been added to the website and they commissioned a privacy risk evaluation from a small consulting firm last year that determined that their risk exposure was relatively low given their current control environment. After reading the consultant’s report, Liam realized that the scope of the assessment was limited to breach notification laws in the US and the Payment Card Industry’s Data Security Standard (PCI DSS).

Not wanting to let down his new team, Liam kept his concerns about the report to himself and figured he could try to put some additional controls into place before the audit. Having some privacy compliance experience in his last role, Liam thought he might start by having discussions with the E-commerce and marketing teams.

The E-commerce Director informed him that they were still using the cookie consent tool forcibly placed on the home screen by the CIO, but could not understand the point since their office was not located in California or Europe. The marketing director touted his department’s success with purchasing email lists and taking a shotgun approach to direct marketing. Both directors highlighted their tracking tools on the website to enhance customer experience while learning more about where else the customer had shopped. The more people Liam met with, the more it became apparent that privacy awareness and the general control environment at Mesa needed help.

With three weeks before the audit, Liam updated Mesa's Privacy Notice himself, which was taken and revised from a competitor’s website. He also wrote policies and procedures outlining the roles and responsibilities for privacy within Mesa and distributed the document to all departments he knew of with access to personal information.

During this time. Liam also filled the backlog of data subject requests for deletion that had been sent to him by the customer service manager. Liam worked with application owners to remove these individual's information and order history from the customer relationship management (CRM) tool, the enterprise resource planning (ERP). the data warehouse and the email server.

At the audit kick-off meeting. Liam explained to his boss and her team that there may still be some room for improvement, but he thought the risk had been mitigated to an appropriate level based on the work he had done thus far.

After the audit had been completed, the audit manager and Liam met to discuss her team’s findings, and much to his dismay. Liam was told that none of the work he had completed prior to the audit followed best practices for governance and risk mitigation. In fact, his actions only opened the company up to additional risk and scrutiny. Based on these findings. Liam worked with external counsel and an established privacy consultant to develop a remediation plan.

All of the key phases of an audit have occurred with Liam's involvement in the situation EXCEPT?

Options:

A.

Prepare.

B.

Audit.

C.

Report.

D.

Follow-up.

Question 23

In a sample metric template, what does “target” mean?

Options:

A.

The suggested volume of data to collect

B.

The percentage of completion

C.

The threshold for a satisfactory rating

D.

The frequency at which the data is sampled

Question 24

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, executive leadership should most likely pay closer attention to what?

Options:

A.

Awareness campaigns with confusing information

B.

Obsolete data processing systems

C.

Outdated security frameworks

D.

Potential in-house threats

Question 25

What are you doing if you succumb to "overgeneralization" when analyzing data from metrics?

Options:

A.

Using data that is too broad to capture specific meanings.

B.

Possessing too many types of data to perform a valid analysis.

C.

Using limited data in an attempt to support broad conclusions.

D.

Trying to use several measurements to gauge one aspect of a program.

Question 26

All of the following are access control measures required by the Payment Card Industry Data Security Standard (PCI DSS) EXCEPT?

Options:

A.

Restrict physical access to cardholder data.

B.

Update antivirus software before granting access.

C.

Assign a unique ID to each person with computer access.

D.

Restrict access to cardholder data by business need-to-know.

Question 27

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 notification, which of the following would be the greatest concern?

Options:

A.

Informing the affected individuals that data from other individuals may have also been affected.

B.

Collecting more personally identifiable information than necessary to provide updates to the affected individuals.

C.

Using a postcard with the logo of the vendor who make the mistake instead of your company’s logo.

D.

Trusting a vendor to send out a notice when they already failed once by not encrypting the database.

Question 28

Under the GDPR. when the applicable lawful basis for the processing of personal data is a legal obligation with which the controller must comply. which right can the data subject exercise?

Options:

A.

Right to withdraw consent.

B.

Right to data portability.

C.

Right to restriction.

D.

Right to erasure.

Question 29

SCENARIO

Please use the following to answer the next QUESTION:

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

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

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

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

Options:

A.

Availability Breach.

B.

Authenticity Breach.

C.

Confidentiality Breach.

D.

Integrity Breach.

Question 30

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?

Options:

A.

The vendor’s representative does not have enough experience

B.

Signing a contract with CRUDLOK which lasts longer than one year

C.

The company did not collect enough identifiers to monitor one’s credit

D.

You are going to notify affected individuals via a letter followed by an email

Question 31

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

Options:

A.

Cost basis.

B.

Gap analysis.

C.

Return to investment.

D.

Breach impact modeling.

Question 32

SCENARIO

Please use the following to answer the next QUESTION:

Perhaps Jack Kelly should have stayed in the U.S. He enjoys a formidable reputation inside the company, Special Handling Shipping, for his work in reforming certain "rogue" offices. Last year, news broke that a police sting operation had revealed a drug ring operating in the Providence, Rhode Island office in the United States. Video from the office's video surveillance cameras leaked to news operations showed a drug exchange between Special Handling staff and undercover officers.

In the wake of this incident, Kelly had been sent to Providence to change the "hands off" culture that upper management believed had let the criminal elements conduct their illicit transactions. After a few weeks under Kelly's direction, the office became a model of efficiency and customer service. Kelly monitored his workers' activities using the same cameras that had recorded the illegal conduct of their former co-workers.

Now Kelly has been charged with turning around the office in Cork, Ireland, another trouble spot. The company has received numerous reports of the staff leaving the office unattended. When Kelly arrived, he found that even when present, the staff often spent their days socializing or conducting personal business on their mobile phones. Again, he observed their behaviors using surveillance cameras. He issued written reprimands to six staff members based on the first day of video alone.

Much to Kelly's surprise and chagrin, he and the company are now under investigation by the Data Protection Commissioner of Ireland for allegedly violating the privacy rights of employees. Kelly was told that the company's license for the cameras listed facility security as their main use, but he does not know why this matters. He has pointed out to his superiors that the company's training programs on privacy protection and data collection mention nothing about surveillance video.

You are a privacy protection consultant, hired by the company to assess this incident, report on the legal and compliance issues, and recommend next steps.

What does this example best illustrate about training requirements for privacy protection?

Options:

A.

Training needs must be weighed against financial costs.

B.

Training on local laws must be implemented for all personnel.

C.

Training must be repeated frequently to respond to new legislation.

D.

Training must include assessments to verify that the material is mastered.

Question 33

A "right to erasure" request could be rejected if the processing of personal data is for?

Options:

A.

An outdated original purpose.

B.

Compliance with legal obligation.

C.

The offer of information society services.

D.

The establishment of personal legal claims.

Question 34

Which of the following is an example of Privacy by Design (PbD)?

Options:

A.

A company hires a professional to structure a privacy program that anticipates the increasing demands of new laws.

B.

The human resources group develops a training program for employees to become certified in privacy policy.

C.

A labor union insists that the details of employers' data protection methods be documented in a new contract.

D.

The information technology group uses privacy considerations to inform the development of new networking software.

Question 35

While trying to e-mail her manager, an employee has e-mailed a list of all the company's customers, including their bank details, to an employee with the same name at a different company. Which of the following would be the first stage in the incident response plan under the General Data Protection Regulation (GDPR)?

Options:

A.

Notification to data subjects.

B.

Containment of impact of breach.

C.

Remediation offers to data subjects.

D.

Notification to the Information Commissioner's Office (ICO).

Question 36

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.

From a business standpoint, what is the most productive way to view employee use of personal equipment for work-related tasks?

Options:

A.

The use of personal equipment is a cost-effective measure that leads to no greater security risks than are always present in a modern organization.

B.

Any computer or other equipment is company property whenever it is used for company business.

C.

While the company may not own the equipment, it is required to protect the business-related data on any equipment used by its employees.

D.

The use of personal equipment must be reduced as it leads to inevitable security risks.

Question 37

When conducting due diligence during an acquisition, what should a privacy professional avoid?

Options:

A.

Discussing with the acquired company the type and scope of their data processing.

B.

Allowing legal in both companies to handle the privacy laws and compliance.

C.

Planning for impacts on the data processing operations post-acquisition.

D.

Benchmarking the two Companies privacy policies against one another.

Question 38

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.

What is the most concerning limitation of the incident-response council?

Options:

A.

You convened it to diffuse blame

B.

The council has an overabundance of attorneys

C.

It takes eight hours of emails to come to a decision

D.

The leader just joined the company as a consultant

Question 39

With whom would it be best for a privacy professional in an organization to consult regarding Privacy-Enhancing Technologies (PETs)?

Options:

A.

A specialist focused on AI.

B.

An independent privacy technology advocate.

C.

An engineer who designs information security technology products.

D.

An information technologist specializing in information privacy technology.

Question 40

Which is the best way to view an organization’s privacy framework?

Options:

A.

As an industry benchmark that can apply to many organizations

B.

As a fixed structure that directs changes in the organization

C.

As an aspirational goal that improves the organization

D.

As a living structure that aligns to changes in the organization

Question 41

When devising effective employee policies to address a particular issue, which of the following should be included in the first draft?

Options:

A.

Rationale for the policy.

B.

Points of contact for the employee.

C.

Roles and responsibilities of the different groups of individuals.

D.

Explanation of how the policy is applied within the organization.

Question 42

SCENARIO

Please use the following to answer the next QUESTION:

Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner, Anton, has found some degree of disorganization after touring the company headquarters. His uncle Henry had always focused on production – not data processing – and Anton is concerned. In several storage rooms, he has found paper files, disks, and old computers that appear to contain the personal data of current and former employees and customers. Anton knows that a single break-in could irrevocably damage the company's

relationship with its loyal customers. He intends to set a goal of guaranteed zero loss of personal information.

To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of the company. However, Kenneth – his uncle's vice president and longtime confidante – wants to hold off on Anton's idea in favor of converting any paper records held at the company to electronic storage. Kenneth believes this process would only take one or two years. Anton likes this idea; he envisions a password- protected system that only he and Kenneth can access.

Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier, but it will simplify the management of the stored data. The heads of subsidiaries like the art gallery and kitchenware store down the street will be responsible for their own information management. Then, any unneeded subsidiary data still in Anton's possession can be destroyed within the next few years.

After learning of a recent security incident, Anton realizes that another crucial step will be notifying customers. Kenneth insists that two lost hard drives in Question are not cause for concern; all of the data was encrypted and not sensitive in nature. Anton does not want to take any chances, however. He intends on sending notice letters to all employees and customers to be safe.

Anton must also check for compliance with all legislative, regulatory, and market requirements related to privacy protection. Kenneth oversaw the development of the company's online presence about ten years ago, but Anton is not confident about his understanding of recent online marketing laws. Anton is assigning another trusted employee with a law background the task of the compliance assessment. After a thorough analysis, Anton knows the company should be safe for another five years, at which time he can order another check.

Documentation of this analysis will show auditors due diligence.

Anton has started down a long road toward improved management of the company, but he knows the effort is worth it. Anton wants his uncle's legacy to continue for many years to come.

Which important principle of Data Lifecycle Management (DLM) will most likely be compromised if Anton executes his plan to limit data access to himself and Kenneth?

Options:

A.

Practicing data minimalism.

B.

Ensuring data retrievability.

C.

Implementing clear policies.

D.

Ensuring adequacy of infrastructure.

Question 43

“Respond” in the privacy operational lifecycle includes which of the following?

Options:

A.

Information security practices and functional area integration.

B.

Privacy awareness training and compliance monitoring.

C.

Communication to stakeholders and alignment to laws.

D.

Information requests and privacy rights requests.

Question 44

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

Options:

A.

It includes a privacy assessment of each major system.

B.

It improves the consistency of the privacy program.

C.

It works at a different type of organization.

D.

It identifies all key stakeholders by name.

Question 45

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?

Options:

A.

The nature of the data elements impacted

B.

The likelihood the incident may lead to harm

C.

The likelihood that the information is accessible and usable

D.

The number of individuals whose information was affected

Question 46

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

Options:

A.

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

B.

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

C.

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

D.

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

Question 47

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

Options:

A.

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

B.

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

C.

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

D.

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

Question 48

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

Options:

A.

Internal unique personal identifiers.

B.

Plain text personal identifiers.

C.

Hashed mobile identifiers.

D.

No personal identifiers.

Question 49

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

Options:

A.

Collection limitation.

B.

Data minimization.

C.

Limitations on liability.

D.

Purpose specification.

Question 50

SCENARIO

Please use the following to answer the next QUESTION:

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

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

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

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

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

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

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

If Amira and Sadie's ideas about adherence to the company's privacy policy go unchecked, the Federal Communications Commission (FCC) could potentially take action against NatGen for what?

Options:

A.

Deceptive practices.

B.

Failing to institute the hotline.

C.

Failure to notify of processing.

D.

Negligence in consistent training.

Question 51

In a mobile app for purchasing and selling concert tickets, users are prompted to create a personalized profile prior to engaging in transactions. Once registered, users can securely access their profiles within the app, empowering them to manage and modify personal data as needed.

Which foundational Privacy by Design (PbD) principle does this feature follow?

Options:

A.

Proactive, not reactive; preventative, not remedial.

B.

Full functionality — positive-sum, not zero-sum.

C.

Respect for user privacy - keep it user-centric.

D.

End-to-end security — full life cycle protection.

Question 52

SCENARIO

Please use the following to answer the next QUESTION:

Your organization, the Chicago (U.S.)-based Society for Urban Greenspace, has used the same vendor to

operate all aspects of an online store for several years. As a small nonprofit, the Society cannot afford the higher-priced options, but you have been relatively satisfied with this budget vendor, Shopping Cart Saver (SCS). Yes, there have been some issues. Twice, people who purchased items from the store have had their credit card information used fraudulently subsequent to transactions on your site, but in neither case did the investigation reveal with certainty that the Society’s store had been hacked. The thefts could have been employee-related.

Just as disconcerting was an incident where the organization discovered that SCS had sold information it had collected from customers to third parties. However, as Jason Roland, your SCS account representative, points out, it took only a phone call from you to clarify expectations and the “misunderstanding” has not occurred again.

As an information-technology program manager with the Society, the role of the privacy professional is only one of many you play. In all matters, however, you must consider the financial bottom line. While these problems with privacy protection have been significant, the additional revenues of sales of items such as shirts and coffee cups from the store have been significant. The Society’s operating budget is slim, and all sources of revenue are essential.

Now a new challenge has arisen. Jason called to say that starting in two weeks, the customer data from the store would now be stored on a data cloud. “The good news,” he says, “is that we have found a low-cost provider in Finland, where the data would also be held. So, while there may be a small charge to pass through to you, it won’t be exorbitant, especially considering the advantages of a cloud.”

Lately, you have been hearing about cloud computing and you know it’s fast becoming the new paradigm for various applications. However, you have heard mixed reviews about the potential impacts on privacy protection. You begin to research and discover that a number of the leading cloud service providers have signed a letter of intent to work together on shared conventions and technologies for privacy protection. You make a note to find out if Jason’s Finnish provider is signing on.

What process can best answer your Questions about the vendor’s data security safeguards?

Options:

A.

A second-party of supplier audit

B.

A reference check with other clients

C.

A table top demonstration of a potential threat

D.

A public records search for earlier legal violations

Question 53

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

Options:

A.

The applicable privacy regulations

B.

The structure of a privacy team

C.

A privacy mission statement

D.

A responsible internal stakeholder

Question 54

The theft of proprietary information could have best been prevented by?

Options:

A.

Doing criminal background checks on all contractors.

B.

Having requests for access reviewed by the privacy office.

C.

Escalating access requests for approval by the appropriate data custodian.

D.

Requiring multi-factor authentication for contractor access to confidential company data.

Question 55

SCENARIO

Please use the following lo answer the next question:

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

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

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

• vehicle registration information:

• facial images of park attendees;

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

The stated purpose of the RFP is to:

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

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

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

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

Options:

A.

Policy creation.

B.

Data minimization.

C.

Sufficient engagement with the privacy team.

D.

Identification of all of the sources, types and uses of personal information

(PI).

Question 56

An organization is establishing a mission statement for its privacy program. Which of the following statements would be the best to use?

Options:

A.

This privacy program encourages cross-organizational collaboration which will stop all data breaches

B.

Our organization was founded in 2054 to reduce the chance of a future disaster like the one that occurred ten years ago. All individuals from our area of the country should be concerned about a future disaster. However, with our privacy program, they should not be concerned about the misuse of their information.

C.

The goal of the privacy program is to protect the privacy of all individuals who support our organization. To meet this goal, we must work to comply with all applicable privacy laws.

D.

In the next 20 years, our privacy program should be able to eliminate 80% of our current breaches. To do this, everyone in our organization must complete our annual privacy training course and all personally identifiable information must be inventoried.

Question 57

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?

Options:

A.

Interview the person reporting the incident following a standard protocol.

B.

Call the police to investigate even if you are unsure a crime occurred.

C.

Investigate the background of the person reporting the incident.

D.

Check company records of the latest backups to see what data may be recoverable.

Question 58

Formosa International operates in 20 different countries including the United States and France. What organizational approach would make complying with a number of different regulations easier?

Options:

A.

Data mapping.

B.

Fair Information Practices.

C.

Rationalizing requirements.

D.

Decentralized privacy management.

Question 59

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?

Options:

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

Question 60

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?

Options:

A.

Cloud Inc. must notify A&M LLP of a data breach immediately.

B.

MessageSafe is liable if Cloud Inc. fails to protect data from A&M LLP.

C.

Cloud Inc. should enter into a data processor agreement with A&M LLP.

D.

A&M LLP's service contract must be amended to list Cloud Inc. as a sub-processor.

Question 61

A Privacy Threshold Analysis (PTA), Privacy Impact Assessment (PIA) and Data Protection Impact Assessment (DPIA) are conducted during what phase of a System Development Life Cycle (SDLC)?

Options:

A.

Testing.

B.

Design.

C.

Deployment.

D.

Maintenance.

Question 62

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

Options:

A.

Keypad or biometric access.

B.

user access reviews.

C.

Encryption.

D.

Tokenization.

Question 63

What is the function of the privacy operational life cycle?

Options:

A.

It establishes initial plans for privacy protection and implementation

B.

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

C.

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

D.

It allows privacy policies to mature to a fixed form

Question 64

You would like to better understand how your organization can demonstrate compliance with international privacy standards and identify gaps for remediation. What steps could you take to achieve this objective?

Options:

A.

Carry out a second-party audit.

B.

Consult your local privacy regulator.

C.

Conduct an annual self assessment.

D.

Engage a third-party to conduct an audit.

Question 65

After an incident, all of the following are potential objectives for improvements to the way an organization handles breach management EXCEPT?

Options:

A.

Contacting regulators.

B.

Reviewing lessons learned.

C.

Ensuring appropriate privacy/security funding.

D.

Getting commitment from stakeholders related to any process updates.

Question 66

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

Options:

A.

Metrics should be reported to the public.

B.

The number of metrics should be limited at first.

C.

Metrics should reveal strategies for increasing company earnings.

D.

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

Question 67

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

Options:

A.

Managing the data flows from parties outside the region.

B.

Establishing legal requirements for privacy protection in the region.

C.

Promoting privacy protection technologies developed in the region.

D.

Promoting consumer trust and business confidence in cross-border data flows.

Question 68

What is one reason the European Union has enacted more comprehensive privacy laws than the United States?

Options:

A.

To ensure adequate enforcement of existing laws.

B.

To ensure there is adequate funding for enforcement.

C.

To allow separate industries to set privacy standards.

D.

To allow the free movement of data between member countries.

Question 69

SCENARIO

Please use the following lo answer the next question:

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

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

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

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

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

Options:

A.

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

B.

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

C.

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

D.

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

Question 70

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.

What metric can Goddard use to assess whether costs associated with implementing new privacy protections are justified?

Options:

A.

Compliance ratio

B.

Cost-effective mean

C.

Return on investment

D.

Implementation measure

Question 71

What is the main purpose in notifying data subjects of a data breach?

Options:

A.

To avoid financial penalties and legal liability.

B.

To enable regulators to understand trends and developments that may shape the law.

C.

To ensure organizations have accountability for the sufficiency of their security measures.

D.

To allow individuals to take any actions required to protect themselves from possible consequences.

Question 72

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 information will be LEAST crucial from a privacy perspective in Penny’s review of vendor contracts?

Options:

A.

Audit rights

B.

Liability for a data breach

C.

Pricing for data security protections

D.

The data a vendor will have access to

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Total 243 questions