Your company wants to convert paper records that contain customer personal information into electronic form, upload the records into a new third-party marketing tool and then merge the customer personal information in the marketing tool with information from other applications.As the Privacy Officer, which of the following should you complete to effectively make these changes?

A Privacy Impact Assessment (PIA).

A Privacy Threshold Analysis (PTA).

A Privacy Impact Assessment (PIA).

A minimum requirement for carrying out a Data Protection Impact Assessment (DPIA) would include?

Processing on a large scale of special categories of data.

Monitoring of a publicly accessible area on a large scale.

Assessment of the necessity and proportionality.

Assessment of security measures.

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

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

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

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

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

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

What is most critical when outsourcing data destruction service?

Obtain a certificate of data destruction.

Confirm data destruction must be done on-site.

Conduct an annual in-person audit of the provider's facilities.

Ensure that they keep an asset inventory of the original data.

Data retention and destruction policies should meet all of the following requirements EXCEPT?

Documentation related to audit controls (third-party or internal) should be saved in a non-permanent format by default.

Data destruction triggers and methods should be documented.

Personal information should be retained only for as long as necessary to perform its stated purpose.

Documentation related to audit controls (third-party or internal) should be saved in a non-permanent format by default.

The organization should be documenting and reviewing policies of its other functions to ensure alignment (e.g. HR, business development, finance, etc.).

What is least likely to be achieved by implementing a Data Lifecycle Management (DLM) program?

Crafting policies which ensure minimal data is collected.

Ensuring data is kept for no longer than necessary.

Crafting policies which ensure minimal data is collected.

Increasing awareness of the importance of confidentiality.

There are different forms of monitoring available for organizations to consider when aligning with their privacy program goals.Which of the following forms of monitoring is best described as 'auditing'?

Evaluating operations, systems, and processes.

Tracking, reporting and documenting complaints from all sources.

Assisting in the completion of attesting reporting for SOC2, ISO, or BS7799.

Ensuring third parties have appropriate security and privacy requirements in place.

Which will best assist you in quickly identifying weaknesses in your network and storage?

Running vulnerability scanning tools.

Reviewing your privacy program metrics.

Reviewing your role-based access controls.

Establishing a complaint-monitoring process.

How do privacy audits differ from privacy assessments?

They are conducted by external parties.

An organization's internal audit team should do all of the following EXCEPT?

Implement processes to correct audit failures.

Verify that technical measures are in place.

Review how operations work in practice.

Ensure policies are being adhered to.

''Respond'' in the privacy operational lifecycle includes which of the following?

Information requests and privacy rights requests.

Information security practices and functional area integration.

Privacy awareness training and compliance monitoring.

Communication to stakeholders and alignment to laws.

Information requests and privacy rights requests.

If your organization has a recurring issue with colleagues not reporting personal data breaches, all of the following are advisable to do EXCEPT?

Distribute a phishing exercise to all employees to test their ability to recognize a threat attempt.

Carry out a root cause analysis on each breach to understand why the incident happened.

Communicate to everyone that breaches must be reported and how they should be reported.

Provide role-specific training to areas where breaches are happening so they are more aware.

Distribute a phishing exercise to all employees to test their ability to recognize a threat attempt.

Which of the following information must be provided by the data controller when complying with GDPR ''right to be informed'' requirements?

The contact details of the Data Protection Officer (DPO).

The purpose of personal data processing.

The data subject's right to withdraw consent

The contact details of the Data Protection Officer (DPO).

The name of any organizations with whom personal data was shared.

If done correctly, how can a Data Protection Impact Assessment (DPIA) create a win/win scenario for organizations and individuals?

By better informing about the risks associated with the processing activity and improving the organization's transparency with individuals.

By quickly identifying potentially problematic data attributes and reducing the risk exposure.

By allowing Data Controllers to solicit feedback from individuals about how they feel about the potential data processing.

By enabling Data Controllers to be proactive in their analysis of processing activities and ensuring compliance with the law.

By better informing about the risks associated with the processing activity and improving the organization's transparency with individuals.

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?

Engage a third-party to conduct an audit.

Carry out a second-party audit.

Consult your local privacy regulator.

Conduct an annual self assessment.

Engage a third-party to conduct an audit.

If your organization has a recurring issue with colleagues not reporting personal data breaches, all of the following are advisable to do EXCEPT?

Distribute a phishing exercise to all employees to test their ability to recognize a threat attempt.

Review reporting activity on breaches to understand when incidents are being reported and when they are not to improve communication and training.

Improve communication to reinforce to everyone that breaches must be reported and how they should be reported.

Provide role-specific training to areas where breaches are happening so they are more aware.

Distribute a phishing exercise to all employees to test their ability to recognize a threat attempt.

A systems audit uncovered a shared drive folder containing sensitive employee data with no access controls and therefore was available for all employees to view. What is the first step to mitigate further risks?

Notify all employees whose information was contained in the file.

Check access logs to see who accessed the folder.

Notify legal counsel of a privacy incident.

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)?

Containment of impact of breach.

Remediation offers to data subjects.

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

Your company provides a SaaS tool for B2B services and does not interact with individual consumers. A client's current employee reaches out with a right to delete request. what is the most appropriate response?

Redirect the individual back to their employer to understand their rights and how this might impact access to company tools.

Forward the request to the contact on file for the client asking them how they would like you to proceed.

Redirect the individual back to their employer to understand their rights and how this might impact access to company tools.

Process the request assuming that the individual understands the implications to their organization if their information is deleted.

Explain you are unable to process the request because business contact information and associated data is not covered under privacy rights laws.

Integrating privacy requirements into functional areas across the organization happens at which stage of the privacy operational life cycle?

Sustaining program performance.

Responding to requests and incidents.

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?

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.

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

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

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

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.

Under the General Data Protection Regulation (GDPR), what are the obligations of a processor that engages a sub-processor?

The processor must obtain the consent of the controller and ensure the sub-processor complies with data processing obligations that are equivalent to those that apply to the processor.

The processor must give the controller prior written notice and perform a preliminary audit of the sub-processor.

The processor must Obtain the controllers specifiC written authorization and provide annual reports on the sub-processor'S performance.

The processor must receive a written agreement that the sub-processor will be fully liable to the controller for the performance of its obligations in relation to the personal data concerned.

The processor must obtain the consent of the controller and ensure the sub-processor complies with data processing obligations that are equivalent to those that apply to the processor.

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

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

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

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

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

Benchmarking the two Companies privacy policies against one another.

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?

Plain text personal identifiers.

Internal unique personal identifiers.

Plain text personal identifiers.

SCENARIOPlease 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?

Include notification provisions in the vendor contract

Arrange regular telephone check-ins reviewing expectations

Send a memorandum of understanding on breach notification

Email the regulations that require breach notifications

What is the function of the privacy operational life cycle?

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

It establishes initial plans for privacy protection and implementation

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

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

It allows privacy policies to mature to a fixed form

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

As a living structure that aligns to changes in the organization

As an industry benchmark that can apply to many organizations

As a fixed structure that directs changes in the organization

As an aspirational goal that improves the organization

As a living structure that aligns to changes in the organization

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

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.

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

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.

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.

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.

SCENARIOPlease 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?

The number of individuals whose information was affected

The nature of the data elements impacted

The likelihood the incident may lead to harm

The likelihood that the information is accessible and usable

The number of individuals whose information was affected

SCENARIOPlease 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?

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

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

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

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

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

SCENARIOPlease 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?

It takes eight hours of emails to come to a decision

You convened it to diffuse blame

The council has an overabundance of attorneys

It takes eight hours of emails to come to a decision

The leader just joined the company as a consultant

SCENARIOPlease 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?

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

The vendor's representative does not have enough experience

Signing a contract with CRUDLOK which lasts longer than one year

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

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

IAPP CIPM Practice Test 4 - Free Online Exam Prep & Questions

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

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