CDPSE Premium Exam Questions

Ensuring appropriate data classification should be done next after a migration of personal data involving a data source with outdated documentation has been approved by senior management, as it helps to identify the types, locations, and owners of the data, and to apply the appropriate privacy controls and measures based on the data classification level. Data classification also facilitates the data discovery, data minimization, data retention, and data disposal processes15. References: 1 Domain 3, Task 2; 5 Page 9

Pseudonymization is a technique that replaces or removes direct identifiers from personal data, such as names, addresses, or social security numbers, with pseudonyms, such as codes, tokens, or random values. However, pseudonymization does not eliminate the possibility of re-identification, as the original data can still be linked back to the pseudonyms using additional information or techniques. Therefore, if a database containing pseudonymized personal data is breached, the IT privacy practitioner should be most concerned about the risk of re-identification, which could compromise the privacy and security of the data subjects. The other options are less relevant or important than the risk of re-identification.

The best answer is D. Assess the organization’s exposure related to the migration.

A comprehensive explanation is:

Before an organization migrates data from an on-premise solution to a cloud-hosted solution that spans more than one jurisdiction, it should first assess its exposure related to the migration. This means that the organization should identify and evaluate the potential risks and benefits of moving its data to the cloud, taking into account the legal, regulatory, contractual, and ethical obligations and implications of doing so.

Some of the factors that the organization should consider in its assessment are:

The nature, sensitivity, and value of the data being migrated, and the impact of its loss, theft, corruption, or disclosure on the organization and its stakeholders.

The security, privacy, and compliance requirements and standards that apply to the data in each jurisdiction where it is stored, processed, or accessed, and the differences or conflicts among them.

The trustworthiness, reliability, and reputation of the cloud service provider and its subcontractors, and the terms and conditions of their service level agreements (SLAs) and contracts.

The availability, performance, scalability, and cost-effectiveness of the cloud-hosted solution compared to the on-premise solution, and the trade-offs involved.

The technical feasibility and complexity of migrating the data from the on-premise solution to the cloud-hosted solution, and the tools and methods needed to do so.

The organizational readiness and capability to manage the change and transition from the on-premise solution to the cloud-hosted solution, and the training and support needed for the staff and users.

By conducting a thorough assessment of its exposure related to the migration, the organization can make an informed decision about whether to proceed with the migration or not, or under what conditions or modifications. The assessment can also help the organization to plan and implement appropriate measures and controls to mitigate or avoid any negative consequences and enhance or maximize any positive outcomes of the migration.

Ensuring data loss prevention (DLP) alerts are turned on (A), encrypting the data while it is being migrated (B), and conducting a penetration test of the hosted solution © are all good practices to protect data privacy and security when migrating data from an on-premise solution to a cloud-hosted solution that spans more than one jurisdiction. However they are not the first steps that should be done before the migration. They are more relevant during or after the migration process. They also do not address other aspects of exposure related to the migration, such as legal, regulatory, contractual, or ethical issues.