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The CIPM exam is a comprehensive and challenging exam that requires a significant amount of preparation and study. The IAPP offers a range of resources and training programs to help candidates prepare for the exam, including online courses, study guides, and practice exams. The IAPP also offers a certification program that recognizes professionals who have passed the CIPM exam and have demonstrated their expertise in privacy management.
Achieving the CIPM certification demonstrates a commitment to the privacy profession and a dedication to staying up-to-date with the latest privacy laws and regulations. It also provides a competitive edge in the job market, as many organizations recognize the value of privacy management and seek out qualified professionals to manage their privacy programs. Whether you are a privacy professional looking to advance your career or an organization seeking to build a strong privacy program, the CIPM certification exam is an excellent way to demonstrate your expertise and stand out in the field.
NEW QUESTION # 101
What is most critical when outsourcing data destruction service?
- A. Ensure that they keep an asset inventory of the original data.
- B. Confirm data destruction must be done on-site.
- C. Conduct an annual in-person audit of the provider's facilities.
- D. Obtain a certificate of data destruction.
Answer: D
Explanation:
Explanation
Obtaining a certificate of data destruction is the most critical step when outsourcing data destruction service.
Data destruction is the process of permanently erasing or destroying personal information from electronic devices or media so that it cannot be recovered or reconstructed. Data destruction is an important part of data protection and retention policies, as it helps prevent unauthorized access, disclosure, or misuse of personal information that is no longer needed or relevant. Outsourcing data destruction service can be convenient and cost-effective for an organization that does not have the resources or expertise to perform it in-house.
However, outsourcing also involves transferring personal information to a third-party provider that may not have the same level of security or accountability as the organization. Therefore, obtaining a certificate of data destruction from the provider is essential to verify that the data destruction has been performed according to the agreed standards and specifications, and that no copies or backups have been retained by the provider. A certificate of data destruction should include information such as: the date and time of the data destruction; the method and level of the data destruction; the serial numbers or identifiers of the devices or media; the name and signature of the person who performed the data destruction; and any relevant laws or regulations that apply to the data destruction.
References:
* CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle Section B:
Protecting Personal Information Subsection 4: Data Retention
* CIPM Study Guide (2021), Chapter 8: Protecting Personal Information Section 8.4: Data Retention
* CIPM Textbook (2019), Chapter 8: Protecting Personal Information Section 8.4: Data Retention
* CIPM Practice Exam (2021), Question 149
NEW QUESTION # 102
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 to prevent the Finnish vendor from transferring data to another party?
- A. Offer company resources to assist with the processing
- B. Restrict the vendor to using company security controls
- C. Lock the data down in its current location
- D. Include transfer prohibitions in the vendor contract
Answer: D
Explanation:
Explanation
This answer is the best way to prevent the Finnish vendor from transferring data to another party, as it can establish clear and binding terms and conditions for both parties regarding their roles and responsibilities for data processing activities. Including transfer prohibitions in the vendor contract can help to define the scope, purpose, duration and type of data processing, as well as the rights and obligations of both parties. The contract can also specify that the vendor is not allowed to share, disclose or transfer the data to any third party without the prior consent or authorization of the organization, and that any breach of this clause may result in legal actions, penalties or termination of the contract.
NEW QUESTION # 103
SCENARIO
Please use the following to answer the next question:
Edufox has hosted an annual convention of users of its famous e-learning software platform, and over time, it has become a grand event. It fills one of the large downtown conference hotels and overflows into the others, with several thousand attendees enjoying three days of presentations, panel discussions and networking. The convention is the centerpiece of the company's product rollout schedule and a great training opportunity for current users. The sales force also encourages prospective clients to attend to get a better sense of the ways in which the system can be customized to meet diverse needs and understand that when they buy into this system, they are joining a community that feels like family.
This year's conference is only three weeks away, and you have just heard news of a new initiative supporting it: a smartphone app for attendees. The app will support late registration, highlight the featured presentations and provide a mobile version of the conference program. It also links to a restaurant reservation system with the best cuisine in the areas featured. "It's going to be great," the developer, Deidre Hoffman, tells you, "if, that is, we actually get it working!" She laughs nervously but explains that because of the tight time frame she'd been given to build the app, she outsourced the job to a local firm. "It's just three young people," she says, "but they do great work." She describes some of the other apps they have built. When asked how they were selected for this job, Deidre shrugs. "They do good work, so I chose them." Deidre is a terrific employee with a strong track record. That's why she's been charged to deliver this rushed project. You're sure she has the best interests of the company at heart, and you don't doubt that she's under pressure to meet a deadline that cannot be pushed back. However, you have concerns about the app's handling of personal data and its security safeguards. Over lunch in the break room, you start to talk to her about it, but she quickly tries to reassure you, "I'm sure with your help we can fix any security issues if we have to, but I doubt there'll be any. These people build apps for a living, and they know what they're doing. You worry too much, but that's why you're so good at your job!" You see evidence that company employees routinely circumvent the privacy officer in developing new initiatives. How can you best draw attention to the scope of this problem?
- A. Develop a metric showing the number of initiatives launched without consultation and include it in reports, presentations, and consultation.
- B. Hold discussions with the department head of anyone who fails to consult with the privacy officer.
- C. Insist upon one-on-one consultation with each person who works around the privacy officer.
- D. Take your concerns straight to the Chief Executive Officer.
Answer: B
NEW QUESTION # 104
A minimum requirement for carrying out a Data Protection Impact Assessment (DPIA) would include?
- A. Assessment of the necessity and proportionality.
- B. Assessment of security measures.
- C. Monitoring of a publicly accessible area on a large scale.
- D. Processing on a large scale of special categories of data.
Answer: D
Explanation:
Explanation
Processing on a large scale of special categories of data is a minimum requirement for carrying out a Data Protection Impact Assessment (DPIA) under the General Data Protection Regulation (GDPR). A DPIA is a type of Privacy Impact Assessment (PIA) that is specifically required by the GDPR when a processing activity is likely to result in a high risk to the rights and freedoms of natural persons. According to Article 35(3)(b) of the GDPR, a DPIA is mandatory when the processing involves a large scale of special categories of data or personal data relating to criminal convictions and offences. Special categories of data are personal data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life or sexual orientation. These types of data are considered more sensitive and require more protection, as they may pose higher risks of discrimination, identity theft, fraud, or other harms to the data subjects.
References:
* CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section C:
Monitoring and Managing Program Performance Subsection 1: Privacy Impact Assessments
* CIPM Study Guide (2021), Chapter 9: Monitoring and Managing Program Performance Section 9.1:
Privacy Impact Assessments
* CIPM Textbook (2019), Chapter 9: Monitoring and Managing Program Performance Section 9.1:
Privacy Impact Assessments
* CIPM Practice Exam (2021), Question 147
* GDPR Article 35(3)(b) and Article 9
NEW QUESTION # 105
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?
- A. Deceptive practices.
- B. Failing to institute the hotline.
- C. Failure to notify of processing.
- D. Negligence in consistent training.
Answer: A
Explanation:
Explanation
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 deceptive practices.
This is because the FCC has the authority to enforce Section 5 of the Federal Trade Commission Act, which prohibits unfair or deceptive acts or practices in or affecting commerce. By allowing different departments to use, collect, store, and dispose of customer data in ways that may not be consistent with the company's privacy policy, NatGen may be misleading its customers about how their personal information is protected and used.
This could violate the FTC Act and expose NatGen to enforcement actions, fines, and reputational damage. References: [FCC Enforcement], [FTC Act], [Privacy Policy]
NEW QUESTION # 106
Which of the documents below assists the Privacy Manager in identifying and responding to a request from an individual about what personal information the organization holds about then with whom the information is shared?
- A. Personal information inventory
- B. Records retention schedule
- C. Privacy policy
- D. Risk register
Answer: B
NEW QUESTION # 107
Under the General Data Protection Regulation (GDPR), which of the following situations would LEAST likely require a controller to notify a data subject?
- A. Personal data of a group of individuals is erroneously sent to the wrong mailing list
- B. An encrypted USB key with sensitive personal data is stolen
- C. A hacker publishes usernames, phone numbers and purchase history online after a cyber-attack
- D. A direct marketing email is sent with recipients visible in the 'cc' field
Answer: B
Explanation:
Explanation
Under the GDPR, a controller must notify a data subject of a personal data breach without undue delay when the breach is likely to result in a high risk to the rights and freedoms of the data subject, unless one of the following conditions applies: the personal data are rendered unintelligible to any person who is not authorized to access it, such as by encryption; the controller has taken subsequent measures to ensure that the high risk is no longer likely to materialize; or the notification would involve disproportionate effort, in which case a public communication or similar measure may suffice. In this case, an encrypted USB key with sensitive personal data is stolen, but the personal data are presumably unintelligible to the thief, so the controller does not need to notify the data subject. However, the controller still needs to notify the supervisory authority within 72 hours of becoming aware of the breach, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons.
References:
* CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section B:
Protecting Personal Information, Subsection 2: Data Breach Incident Planning and Management
* CIPM Study Guide (2021), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach
* Incident Planning and Management
* CIPM Textbook (2019), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management
* CIPM Practice Exam (2021), Question 134
* GDPR Article 33 and 3412
NEW QUESTION # 108
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.
You give a presentation to your CEO about privacy program maturity. What does it mean to have a "managed" privacy program, according to the AICPA/CICA Privacy Maturity Model?
- A. Regular review and feedback are used to ensure continuous improvement toward optimization of the given process.
- B. Procedures or processes exist, however they are not fully documented and do not cover all relevant aspects.
- C. Reviews are conducted to assess the effectiveness of the controls in place.
- D. Procedures and processes are fully documented and implemented, and cover all relevant aspects.
Answer: D
Explanation:
Explanation
This answer is the best way to describe what it means to have a "managed" privacy program, according to the AICPA/CICA Privacy Maturity Model (PMM), which is a framework that measures the effectiveness and maturity of an organization's privacy program based on five phases: ad hoc, repeatable, defined, managed and optimized. The managed phase is the fourth level of maturity in the PMM, which indicates that the organization has a formal and consistent approach to privacy protection and that its privacy practices are aligned with its policies and objectives. The managed phase means that the organization has procedures and processes that are fully documented and implemented, and cover all relevant aspects of data collection, use, storage, protection, sharing and disposal. The managed phase also means that the organization has controls and measures that are monitored and evaluated regularly, and that any issues or incidents are reported and resolved promptly.
NEW QUESTION # 109
Under the General Data Protection Regulation (GDPR), when would a data subject have the right to require the erasure of his or her data without undue delay?
- A. When the data is no longer necessary for its original purpose
- B. When the processing is carried out by automated means
- C. When the data subject is a public authority
- D. When the erasure is in the public interest
Answer: C
NEW QUESTION # 110
Which of the following is NOT an important factor to consider when developing a data retention policy?
- A. Technology resource.
- B. Compliance requirement
- C. Business requirement.
- D. Organizational culture.
Answer: D
Explanation:
Explanation
Organizational culture is not an important factor to consider when developing a data retention policy. A data retention policy is a document that defines how long an organization retains personal information for various purposes and how it disposes of it securely when it is no longer needed. A data retention policy should be based on factors such as: business requirements, such as operational needs, customer expectations, contractual obligations, or industry standards; compliance requirements, such as legal obligations, regulatory mandates, or audit recommendations; and technology resources, such as storage capacity, backup systems, encryption methods, or disposal tools. Organizational culture, which refers to the values, beliefs, norms, and behaviors that shape how an organization operates and interacts with its stakeholders, is not a relevant factor for determining data retention periods or disposal methods.
References:
* CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section B:
Protecting Personal Information, Subsection 4: Data Retention
* CIPM Study Guide (2021), Chapter 8: Protecting Personal Information, Section 8.4: Data Retention
* CIPM Textbook (2019), Chapter 8: Protecting Personal Information, Section 8.4: Data Retention
* CIPM Practice Exam (2021), Question 141
NEW QUESTION # 111
SCENARIO
Please use the following to answer the next question:
Martin Briseno is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseno decided to change the hotel's on-the-job mentoring model to a standardized training program for employees who were progressing from line positions into supervisory positions. He developed a curriculum comprising a series of lessons, scenarios, and assessments, which was delivered in-person to small groups. Interest in the training increased, leading Briseno to work with corporate HR specialists and software engineers to offer the program in an online format. The online program saved the cost of a trainer and allowed participants to work through the material at their own pace.
Upon hearing about the success of Briseno's program, Pacific Suites corporate Vice President Maryanne Silva-Hayes expanded the training and offered it company-wide. Employees who completed the program received certification as a Pacific Suites Hospitality Supervisor. By 2001, the program had grown to provide industry-wide training. Personnel at hotels across the country could sign up and pay to take the course online.
As the program became increasingly profitable, Pacific Suites developed an offshoot business, Pacific Hospitality Training (PHT). The sole focus of PHT was developing and marketing a variety of online courses and course progressions providing a number of professional certifications in the hospitality industry.
By setting up a user account with PHT, course participants could access an information library, sign up for courses, and take end-of-course certification tests. When a user opened a new account, all information was saved by default, including the user's name, date of birth, contact information, credit card information, employer, and job title. The registration page offered an opt-out choice that users could click to not have their credit card numbers saved. Once a user name and password were established, users could return to check their course status, review and reprint their certifications, and sign up and pay for new courses. Between 2002 and
2008, PHT issued more than 700,000 professional certifications.
PHT's profits declined in 2009 and 2010, the victim of industry downsizing and increased competition from e- learning providers. By 2011, Pacific Suites was out of the online certification business and PHT was dissolved.
The training program's systems and records remained in Pacific Suites' digital archives, un-accessed and unused. Briseno and Silva-Hayes moved on to work for other companies, and there was no plan for handling the archived data after the program ended. After PHT was dissolved, Pacific Suites executives turned their attention to crucial day-to-day operations. They planned to deal with the PHT materials once resources allowed.
In 2012, the Pacific Suites computer network was hacked. Malware installed on the online reservation system exposed the credit card information of hundreds of hotel guests. While targeting the financial data on the reservation site, hackers also discovered the archived training course data and registration accounts of Pacific Hospitality Training's customers. The result of the hack was the exfiltration of the credit card numbers of recent hotel guests and the exfiltration of the PHT database with all its contents.
A Pacific Suites systems analyst discovered the information security breach in a routine scan of activity reports. Pacific Suites quickly notified credit card companies and recent hotel guests of the breach, attempting to prevent serious harm. Technical security engineers faced a challenge in dealing with the PHT data.
PHT course administrators and the IT engineers did not have a system for tracking, cataloguing, and storing information. Pacific Suites has procedures in place for data access and storage, but those procedures were not implemented when PHT was formed. When the PHT database was acquired by Pacific Suites, it had no owner or oversight. By the time technical security engineers determined what private information was compromised, at least 8,000 credit card holders were potential victims of fraudulent activity.
What must Pacific Suite's primary focus be as it manages this security breach?
- A. Investigating the cause and assigning responsibility
- B. Maintaining operations and preventing publicity
- C. Minimizing the amount of harm to the affected individuals
- D. Determining whether the affected individuals should be notified
Answer: C
NEW QUESTION # 112
When supporting the business and data privacy program expanding into a new jurisdiction, it is important to do all of the following EXCEPT?
- A. Perform an assessment of the laws applicable in that new jurisdiction.
- B. Appoint a new Privacy Officer (PO) for that jurisdiction.
- C. Consider culture and whether the privacy framework will need to account for changes in culture.
- D. Identify the stakeholders.
Answer: B
Explanation:
Explanation
When expanding into a new jurisdiction, it is not necessary to appoint a new Privacy Officer (PO) for that jurisdiction, unless the local law requires it. The other options are important steps to ensure compliance with the new jurisdiction's privacy laws and regulations, as well as to align the privacy program with the business objectives and culture of the new market. References: CIPM Body of Knowledge, Domain I: Privacy Program Governance, Task 1: Establish the privacy program vision and strategy.
NEW QUESTION # 113
SCENARIO
Please use the following to answer the next question:
As the director of data protection for Consolidated Records Corporation, you are justifiably pleased with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of relatively minor data breaches that could easily have been worse. However, you have not had a reportable incident for the three years that you have been with the company. In fact, you consider your program a model that others in the data storage industry may note in their own program development.
You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward coherence across departments and throughout operations. You were aided along the way by the program's sponsor, the vice president of operations, as well as by a Privacy Team that started from a clear understanding of the need for change.
Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard" among both the executive team and frontline personnel working with data and interfacing with clients. Through the use of metrics that showed the costs not only of the breaches that had occurred, but also projections of the costs that easily could occur given the current state of operations, you soon had the leaders and key decision-makers largely on your side. Many of the other employees were more resistant, but face-to-face meetings with each department and the development of a baseline privacy training program achieved sufficient
"buy-in" to begin putting the proper procedures into place.
Now, privacy protection is an accepted component of all current operations involving personal or protected data and must be part of the end product of any process of technological development. While your approach is not systematic, it is fairly effective.
You are left contemplating: What must be done to maintain the program and develop it beyond just a data breach prevention program? How can you build on your success? What are the next action steps?
What process could most effectively be used to add privacy protections to a new, comprehensive program being developed at Consolidated?
- A. Privacy by Design
- B. Innovation Privacy Standards
- C. Privacy Step Assessment
- D. Information Security Planning
Answer: D
NEW QUESTION # 114
Read the following steps:
* Perform frequent data back-ups.
* Perform test restorations to verify integrity of backed-up data.
* Maintain backed-up data offline or on separate servers.
These steps can help an organization recover from what?
- A. Stolen encryption keys
- B. Phishing attacks
- C. Authorization errors
- D. Ransomware attacks
Answer: D
Explanation:
Explanation
The steps of performing frequent data back-ups, performing test restorations to verify integrity of backed-up data, and maintaining backed-up data offline or on separate servers can help an organization recover from ransomware attacks. Ransomware is a type of malicious software that encrypts the victim's data and demands a ransom for the decryption key. Ransomware attacks can cause significant disruption, damage, and financial losses to an organization, as well as compromise the confidentiality, integrity, and availability of personal information. Having a reliable and secure backup system can help an organization restore its data and resume its operations without paying the ransom or losing valuable information.
References:
* CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section B:
Protecting Personal Information, Subsection 1: Information Security Practices
* CIPM Study Guide (2021), Chapter 8: Protecting Personal Information, Section 8.1: Information Security Practices
* CIPM Textbook (2019), Chapter 8: Protecting Personal Information, Section 8.1: Information Security Practices
* CIPM Practice Exam (2021), Question 129
NEW QUESTION # 115
Which statement is FALSE regarding the use of technical security controls?
- A. A person with security knowledge should be involved with the deployment of technical security controls.
- B. Technical security controls deployed for one jurisdiction often satisfy another jurisdiction.
- C. Most privacy legislation lists the types of technical security controls that must be implemented.
- D. Technical security controls are part of a data governance strategy.
Answer: C
Explanation:
Explanation
The statement that is false regarding the use of technical security controls is that most privacy legislation lists the types of technical security controls that must be implemented. Technical security controls are the hardware and software components that protect a system against cyberattacks, such as encryption, firewalls, antivirus software, and access control mechanisms1 However, most privacy legislation does not prescribe specific types of technical security controls that must be implemented by organizations. Instead, they usually require organizations to implement reasonable or appropriate technical security measures to protect personal data from unauthorized or unlawful access, use, disclosure, alteration, or destruction23 The exact level and type of technical security controls may depend on various factors, such as the nature and sensitivity of the data, the risks and threats involved, the state of the art technology available, and the cost and feasibility of implementation4 Therefore, organizations have some flexibility and discretion in choosing the most suitable technical security controls for their data processing activities. References: 1: Technical Controls - Cybersecurity Resilience - Resilient Energy Platform; 2: [General Data Protection Regulation (GDPR) - Official Legal Text], Article 32; 3: [Privacy Act 1988], Schedule 1 - Australian Privacy Principles (APPs), APP 11; 4: Technical Security Controls: Encryption, Firewalls & More
NEW QUESTION # 116
SCENARIO
Please use the following to answer the next question:
John is the new privacy officer at the prestigious international law firm - A&M LLP. A&M LLP is very proud of its reputation in the practice areas of Trusts & Estates and Merger & Acquisition in both U.S. and Europe. During lunch with a colleague from the Information Technology department, John heard that the Head of IT, Derrick, is about to outsource the firm's email continuity service to their existing email security vendor - MessageSafe.
Being successful as an email hygiene vendor, MessageSafe is expanding its business by leasing cloud infrastructure from Cloud Inc. to host email continuity service for A&M LLP.
John is very concerned about this initiative. He recalled that MessageSafe was in the news six months ago due to a security breach. Immediately, John did a quick research of MessageSafe's previous breach and learned that the breach was caused by an unintentional mistake by an IT administrator. He scheduled a meeting with Derrick to address his concerns.
At the meeting, Derrick emphasized that email is the primary method for the firm's lawyers to communicate with clients, thus it is critical to have the email continuity service to avoid any possible email downtime. Derrick has been using the anti-spam service provided by MessageSafe for five years and is very happy with the quality of service provided by MessageSafe. In addition to the significant discount offered by MessageSafe, Derrick emphasized that he can also speed up the onboarding process since the firm already has a service contract in place with MessageSafe. The existing on-premises email continuity solution is about to reach its end of life very soon and he doesn't have the time or resource to look for another solution. Furthermore, the off- premises email continuity service will only be turned on when the email service at A&M LLP's primary and secondary data centers are both down, and the email messages stored at MessageSafe site for continuity service will be automatically deleted after 30 days.
Which of the following is a TRUE statement about the relationship among the organizations?
- A. A&M LLP's service contract must be amended to list Cloud Inc. as a sub-processor.
- B. Cloud Inc. must notify A&M LLP of a data breach immediately.
- C. Cloud Inc. should enter into a data processor agreement with A&M LLP.
- D. MessageSafe is liable if Cloud Inc. fails to protect data from A&M LLP.
Answer: B
NEW QUESTION # 117
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.
To improve the facility's system of data security, Anton should consider following through with the plan for which of the following?
- A. Employee advisement regarding legal matters.
- B. Employee access to electronic storage.
- C. Controlled access at the company headquarters.
- D. Customer communication.
Answer: C
Explanation:
Explanation
To improve the facility's system of data security, Anton should consider following through with the plan for controlled access at the company headquarters. This plan would help to prevent unauthorized physical access to the paper files, disks, and old computers that contain personal data of employees and customers. Physical security is an important aspect of data security that involves protecting hardware and storage devices from theft, damage, or tampering1 By placing restrictions on who can enter the premises or access certain areas or rooms, Anton can reduce the risk of data breaches or incidents caused by intruders or insiders2 He can also implement locks, alarms, cameras, or guards to enhance the physical security of the facility3 References: 1: Physical Security: What Is It?; 2: [Physical Security: Why It's Important & How To Implement It]; 3: [Physical Security Best Practices: 10 Tips to Secure Your Workplace]
NEW QUESTION # 118
SCENARIO
Please use the following to answer the next question:
Martin Briseno is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseno decided to change the hotel's on-the-job mentoring model to a standardized training program for employees who were progressing from line positions into supervisory positions. He developed a curriculum comprising a series of lessons, scenarios, and assessments, which was delivered in-person to small groups. Interest in the training increased, leading Briseno to work with corporate HR specialists and software engineers to offer the program in an online format. The online program saved the cost of a trainer and allowed participants to work through the material at their own pace.
Upon hearing about the success of Briseno's program, Pacific Suites corporate Vice President Maryanne Silva-Hayes expanded the training and offered it company-wide. Employees who completed the program received certification as a Pacific Suites Hospitality Supervisor. By 2001, the program had grown to provide industry-wide training. Personnel at hotels across the country could sign up and pay to take the course online.
As the program became increasingly profitable, Pacific Suites developed an offshoot business, Pacific Hospitality Training (PHT). The sole focus of PHT was developing and marketing a variety of online courses and course progressions providing a number of professional certifications in the hospitality industry.
By setting up a user account with PHT, course participants could access an information library, sign up for courses, and take end-of-course certification tests. When a user opened a new account, all information was saved by default, including the user's name, date of birth, contact information, credit card information, employer, and job title. The registration page offered an opt-out choice that users could click to not have their credit card numbers saved. Once a user name and password were established, users could return to check their course status, review and reprint their certifications, and sign up and pay for new courses. Between 2002 and
2008, PHT issued more than 700,000 professional certifications.
PHT's profits declined in 2009 and 2010, the victim of industry downsizing and increased competition from e- learning providers. By 2011, Pacific Suites was out of the online certification business and PHT was dissolved.
The training program's systems and records remained in Pacific Suites' digital archives, un-accessed and unused. Briseno and Silva-Hayes moved on to work for other companies, and there was no plan for handling the archived data after the program ended. After PHT was dissolved, Pacific Suites executives turned their attention to crucial day-to-day operations. They planned to deal with the PHT materials once resources allowed.
In 2012, the Pacific Suites computer network was hacked. Malware installed on the online reservation system exposed the credit card information of hundreds of hotel guests. While targeting the financial data on the reservation site, hackers also discovered the archived training course data and registration accounts of Pacific Hospitality Training's customers. The result of the hack was the exfiltration of the credit card numbers of recent hotel guests and the exfiltration of the PHT database with all its contents.
A Pacific Suites systems analyst discovered the information security breach in a routine scan of activity reports. Pacific Suites quickly notified credit card companies and recent hotel guests of the breach, attempting to prevent serious harm. Technical security engineers faced a challenge in dealing with the PHT data.
PHT course administrators and the IT engineers did not have a system for tracking, cataloguing, and storing information. Pacific Suites has procedures in place for data access and storage, but those procedures were not implemented when PHT was formed. When the PHT database was acquired by Pacific Suites, it had no owner or oversight. By the time technical security engineers determined what private information was compromised, at least 8,000 credit card holders were potential victims of fraudulent activity.
In the Information Technology engineers had originally set the default for customer credit card information to
"Do Not Save," this action would have been in line with what concept?
- A. Use limitation
- B. Privacy by Design
- C. Harm minimization
- D. Reactive risk management
Answer: B
NEW QUESTION # 119
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 has 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 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.
In terms of compliance with regulatory and legislative changes, Anton has a misconception regarding?
- A. The use of internal employees
- B. The method of recordkeeping
- C. The timeline for monitoring
- D. The type of required qualifications
Answer: B
NEW QUESTION # 120
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 practice would afford the Director the most rigorous way to check on the program's compliance with laws, regulations and industry best practices?
- A. Monitoring
- B. Auditing
- C. Assessment
- D. Forensics
Answer: A
NEW QUESTION # 121
You would like your organization to be independently audited to demonstrate compliance with international privacy standards and to identify gaps for remediation.
Which type of audit would help you achieve this objective?
- A. Second-party audit.
- B. First-party audit.
- C. Fourth-party audit.
- D. Third-party audit.
Answer: D
Explanation:
Explanation
A third-party audit would help an organization achieve the objective of demonstrating compliance with international privacy standards and identifying gaps for remediation. A third-party audit is an audit conducted by an independent and external auditor who is not affiliated with either the audited organization or its customers. A third-party audit can provide an objective and impartial assessment of the organization's privacy practices and policies, as well as verify its compliance with relevant standards and regulations. A third-party audit can also help the organization identify areas for improvement and recommend corrective actions. A third-party audit can enhance the organization's reputation, trustworthiness, and credibility among its stakeholders and customers.
A first-party audit is an audit conducted by the organization itself or by someone within the organization who has been designated as an auditor. A first-party audit is also known as an internal audit. A first-party audit can help the organization monitor its own performance, evaluate its compliance with internal policies and procedures, and identify potential risks and opportunities for improvement. However, a first-party audit may not be sufficient to demonstrate compliance with external standards and regulations, as it may lack independence and objectivity.
A second-party audit is an audit conducted by a party that has an interest in or a relationship with the audited organization, such as a customer, a supplier, or a partner. A second-party audit is also known as an external audit. A second-party audit can help the party verify that the audited organization meets its contractual obligations, expectations, and requirements. A second-party audit can also help the party evaluate the quality and reliability of the audited organization's products or services. However, a second-party audit may not be able to provide a comprehensive and unbiased assessment of the audited organization's privacy practices and policies, as it may be influenced by the party's own interests and objectives. References: Types of Audits: 14 Types of Audits and Level of Assurance (2022)
NEW QUESTION # 122
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IAPP CIPM Exam is a comprehensive certification program that covers all aspects of privacy program management, from governance to risk management to operations. Passing the CIPM exam is a significant achievement and a valuable asset for privacy professionals and organizations alike. If you are responsible for managing privacy programs, obtaining the CIPM certification can help validate your knowledge and expertise and advance your career in the privacy profession.
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