CIPP-US Reviews Questions

The strongest example of excessive monitoring by the employer is C. An employer who installs video monitors in physical locations, such as a changing room, to reduce the risk of sexual harassment. This would be considered an unreasonable invasion of employees’ privacy, as it would violate their legitimate expectation of privacy in a place where they change their clothes. Such monitoring would also likely violate the Electronic Communications Privacy Act (ECPA), which prohibits the interception of oral communications without consent or authorization. Moreover, such monitoring would not be justified by a legitimate business interest, as there are less intrusive ways to prevent or address sexual harassment, such as policies, training, and reporting mechanisms. References:

• [IAPP CIPP/US Study Guide], Chapter 4: Workplace Privacy, pp. 109-110.
• IAPP CIPP/US Body of Knowledge, Section IV: Workplace Privacy, Subsection A: Employee Privacy Expectations, Topic 1: Employee Monitoring.
• IAPP CIPP/US Practice Questions, Question 134.

The GLBA prohibits financial institutions from disclosing a consumer’s account number or similar form of access number or access code to any nonaffiliated third party for use in telemarketing, direct mail marketing, or other marketing through electronic mail to the consumer. This restriction is intended to prevent unauthorized access to a person’s bank account by third parties who may use the account number to initiate fraudulent transactions or identity theft. The GLBA also requires financial institutions to implement safeguards to protect the security, confidentiality, and integrity of customer information, and to notify customers and regulators in the event of a security breach involving such information. References:

• IAPP CIPP/US Certified Information Privacy Professional Study Guide, Chapter 2: Limits on Private-sector Collection and Use of Data, Section 2.3: Financial Privacy, p. 49-50
• IAPP CIPP/US Body of Knowledge, Domain II: Limits on Private-sector Collection and Use of Data, Objective II.C: Identify the privacy requirements for financial institutions, Subobjective II.C.2: Identify the restrictions on disclosure of account numbers, p. 14
• IAPP CIPP/US Exam Blueprint, Domain II: Limits on Private-sector Collection and Use of Data, Objective II.C: Identify the privacy requirements for financialinstitutions, Subobjective II.C.2: Identify the restrictions on disclosure of account numbers, p. 5

The Consumer Privacy Bill of Rights is a set of principles proposed by the Obama administration in 2012 to protect the privacy of consumers online and offline. The principles are based on the Fair Information Practice Principles, which are widely accepted as the foundation of privacy protection. One of the principles is the right to reasonable limits on the personal data that a company retains, which means that companies should collect and keep only the personal data they need for legitimate purposes, and dispose of it securely when it is no longer needed. This principle would best reform the company’s privacy program in the scenario, as it would address the major concerns that Roberta identified in her report, such as the lack of rules and procedures for purging and destroying outdated data, and the excessive access to customer information by low-level employees. By implementing reasonable limits on the personal data that the company retains, the company would reduce the risk of data breaches, enhance customer trust, and comply with state breach notification laws. References:

• Fact Sheet: Plan to Protect Privacy in the Internet Age by Adopting a Consumer Privacy Bill of Rights
• IAPP CIPP/US Certified Information Privacy Professional Study Guide, Chapter 1: Introduction to U.S. Privacy Law, Section 1.2: The Consumer Privacy Bill of Rights

The best way for Otto to minimize the privacy risks involved in using a cloud provider for the HR data is to ensure that the cloud provider abides by the contractual requirements by conducting an on-site audit. This would allow Otto to verify that the cloud provider has implemented adequate security measures, such as encryption, access controls, and backup systems, to protect the HR data from unauthorized access, use, or disclosure. It would also allow Otto to check that the cloud provider is complying with the applicable privacy laws and regulations, such as the CCPA, the APEC Privacy Framework, and the breach notification requirements. By conducting an on-site audit, Otto can identify any gaps or weaknesses in the cloud provider’s privacy practices and address them promptly. This would also demonstrate due diligence and accountability on the part of Filtration Station, which could mitigate the legal and reputational consequences of a data breach. References:

• [IAPP CIPP/US Study Guide], Chapter 3: Data Assessments, pp. 77-78.
• IAPP CIPP/US Body of Knowledge, Section III: Government and Court Access to Private-sector Information, Subsection B: Cross-Border Data Transfer, Topic 2: APEC Privacy Framework.
• IAPP CIPP/US Practice Questions, Question 125.