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SCENARIO

Please use the following to answer the next QUESTION:

Martin Briseo is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseo 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 Briseo 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 Briseo'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. Briseo 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.

How would a strong data life cycle management policy have helped prevent the breach?

A.

Information would have been ranked according to importance and stored in separate locations

A.

Information would have been ranked according to importance and stored in separate locations

Answers
B.

The most sensitive information would have been immediately erased and destroyed

B.

The most sensitive information would have been immediately erased and destroyed

Answers
C.

The most important information would have been regularly assessed and tested for security

C.

The most important information would have been regularly assessed and tested for security

Answers
D.

Information would have been categorized and assigned a deadline for destruction

D.

Information would have been categorized and assigned a deadline for destruction

Answers
Suggested answer: D

SCENARIO

Please use the following to answer the next QUESTION:

Martin Briseo is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseo 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 Briseo 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 Briseo'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. Briseo 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.

How was Pacific Suites responsible for protecting the sensitive information of its offshoot, PHT?

A.

As the parent company, it should have transferred personnel to oversee the secure handling of PHT's data.

A.

As the parent company, it should have transferred personnel to oversee the secure handling of PHT's data.

Answers
B.

As the parent company, it should have performed an assessment of PHT's infrastructure and confirmed complete separation of the two networks.

B.

As the parent company, it should have performed an assessment of PHT's infrastructure and confirmed complete separation of the two networks.

Answers
C.

As the parent company, it should have ensured its existing data access and storage procedures were integrated into PHT's system.

C.

As the parent company, it should have ensured its existing data access and storage procedures were integrated into PHT's system.

Answers
D.

As the parent company, it should have replaced PHT's electronic files with hard-copy documents stored securely on site.

D.

As the parent company, it should have replaced PHT's electronic files with hard-copy documents stored securely on site.

Answers
Suggested answer: C

SCENARIO

Please use the following to answer the next QUESTION:

Martin Briseo is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseo 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 Briseo 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 Briseo'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. Briseo 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.

Minimizing the amount of harm to the affected individuals

A.

Minimizing the amount of harm to the affected individuals

Answers
B.

Investigating the cause and assigning responsibility

B.

Investigating the cause and assigning responsibility

Answers
C.

Determining whether the affected individuals should be notified

C.

Determining whether the affected individuals should be notified

Answers
D.

Maintaining operations and preventing publicity

D.

Maintaining operations and preventing publicity

Answers
Suggested answer: A

A Human Resources director at a company reported that a laptop containing employee payroll data was lost on the train. Which action should the company take IMMEDIATELY?

A.

Report the theft to law enforcement

A.

Report the theft to law enforcement

Answers
B.

Wipe the hard drive remotely

B.

Wipe the hard drive remotely

Answers
C.

Report the theft to the senior management

C.

Report the theft to the senior management

Answers
D.

Perform a multi-factor risk analysis

D.

Perform a multi-factor risk analysis

Answers
Suggested answer: D

Explanation:

The company should perform a multi-factor risk analysis immediately after discovering the loss of the laptop containing employee payroll data. A multi-factor risk analysis is a process of assessing the potential impact and likelihood of a data breach, taking into account various factors such as the nature, scope, context, and purpose of the processing, the type and severity of the harm that may result from the breach, the number and categories of data subjects and personal data affected, the measures taken to mitigate the risk, and any relevant legal obligations or codes of conduct.A multi-factor risk analysis can help the company determine whether the breach poses a high risk to the rights and freedoms of the data subjects, and whether it needs to notify them and/or the relevant supervisory authority without undue delay, as required by Article 33 and 34 of the GDPR1. A multi-factor risk analysis can also help the company identify the root cause of the breach, evaluate the effectiveness of its existing security measures, and implement appropriate corrective actions to prevent or minimize similar incidents in the future.

CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section B: Protecting Personal Information, Subsection 2: Data Breach Incident Planning and Management2

CIPM Study Guide (2021), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management3

CIPM Textbook (2019), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management4

CIPM Practice Exam (2021), Question 1285

GDPR Article 33 and 341

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.

Phishing attacks

A.

Phishing attacks

Answers
B.

Authorization errors

B.

Authorization errors

Answers
C.

Ransomware attacks

C.

Ransomware attacks

Answers
D.

Stolen encryption keys

D.

Stolen encryption keys

Answers
Suggested answer: C

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.

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

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

A.

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

A.

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

Answers
B.

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

B.

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

Answers
C.

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

C.

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

Answers
D.

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

D.

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

Answers
Suggested answer: B

Explanation:

The GDPR specifies fines that may be levied against data controllers for certain infringements. According to Article 83(4)(a) of the GDPR, failure to implement technical and organizational measures to ensure data protection is enshrined by design and default will be subject to administrative fines of up to 10 000 000 EUR, or in the case of an undertaking, up to 2% of the total worldwide annual turnover of the preceding financial year, whichever is higher. Data protection by design and default is a principle that requires data controllers to integrate data protection considerations into every stage of the processing activities, from the conception to the execution, and to adopt appropriate measures to safeguard the rights and interests of the data subjects by default, such as minimizing the amount and retention period of personal data, pseudonymizing or encrypting personal data, ensuring transparency and accountability, and enabling data subject rights.

CIPM Body of Knowledge (2021), Domain I: Privacy Program Governance, Section A: Privacy Governance Models, Subsection 2: Privacy by Design

CIPM Study Guide (2021), Chapter 2: Privacy Governance Models, Section 2.2: Privacy by Design

CIPM Textbook (2019), Chapter 2: Privacy Governance Models, Section 2.2: Privacy by Design

CIPM Practice Exam (2021), Question 130

GDPR Article 83(4)(a) and Article 25

SCENARIO

Please use the following to answer the next QUESTION.

Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can be used in the home to manage family calendars, do online shopping, and schedule doctor appointments.

After having had a successful launch in the United States, the Handy Helper is about to be made available for purchase worldwide.

The packaging and user guide for the Handy Helper indicate that it is a ''privacy friendly'' product suitable for the whole family, including children, but does not provide any further detail or privacy notice. In order to use the application, a family creates a single account, and the primary user has access to all information about the other users. Upon start up, the primary user must check a box consenting to receive marketing emails from Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.

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

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

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

What security controls are missing from the Eureka program?

A.

Storage of medical data in the cloud is not permissible under the General Data Protection Regulation (GDPR)

A.

Storage of medical data in the cloud is not permissible under the General Data Protection Regulation (GDPR)

Answers
B.

Data access is not limited to those who ''need to know'' for their role

B.

Data access is not limited to those who ''need to know'' for their role

Answers
C.

Collection of data without a defined purpose might violate the fairness principle

C.

Collection of data without a defined purpose might violate the fairness principle

Answers
D.

Encryption of the data at rest prevents European users from having the right of access and the right of portability of their data

D.

Encryption of the data at rest prevents European users from having the right of access and the right of portability of their data

Answers
Suggested answer: B

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

A.

To avoid financial penalties and legal liability

A.

To avoid financial penalties and legal liability

Answers
B.

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

B.

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

Answers
C.

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

C.

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

Answers
D.

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

D.

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

Answers
Suggested answer: D

Explanation:

The main purpose in notifying data subjects of a data breach is to allow individuals to take any actions required to protect themselves from possible consequences, such as identity theft, fraud, or discrimination. This is consistent with the principle of transparency and the right to information under the GDPR. The other options are not the main purpose of notification, although they may be secondary effects or benefits of the process.Reference:

Data protection impact assessments | ICO

[Art. 34 GDPR -- Communication of a personal data breach to the data subject - GDPR.eu]

Under the General Data Protection Regulation (GDPR), which situation would be LEAST likely to require a Data Protection Impact Assessment (DPIA)?

A.

A health clinic processing its patients' genetic and health data

A.

A health clinic processing its patients' genetic and health data

Answers
B.

The use of a camera system to monitor driving behavior on highways

B.

The use of a camera system to monitor driving behavior on highways

Answers
C.

A Human Resources department using a tool to monitor its employees' internet activity

C.

A Human Resources department using a tool to monitor its employees' internet activity

Answers
D.

An online magazine using a mailing list to send a generic daily digest to marketing emails

D.

An online magazine using a mailing list to send a generic daily digest to marketing emails

Answers
Suggested answer: D

Explanation:

A Data Protection Impact Assessment (DPIA) is a process to help identify and minimize the data protection risks of a project. Under the GDPR, a DPIA is required when the processing is likely to result in a high risk to the rights and freedoms of individuals, especially when using new technologies. The GDPR provides some examples of high-risk processing activities, such as systematic and extensive evaluation of personal aspects, large-scale processing of special categories of data, or systematic monitoring of public areas. The other options are more likely to require a DPIA than the online magazine using a mailing list to send a generic daily digest to marketing emails, as they involve more sensitive or intrusive types of processing.Reference:

[Data protection impact assessments | ICO]

[Art. 35 GDPR -- Data protection impact assessment - GDPR.eu]

Under the General Data Protection Regulation (GDPR), which of the following situations would LEAST likely require a controller to notify a data subject?

A.

An encrypted USB key with sensitive personal data is stolen

A.

An encrypted USB key with sensitive personal data is stolen

Answers
B.

A direct marketing email is sent with recipients visible in the 'cc' field

B.

A direct marketing email is sent with recipients visible in the 'cc' field

Answers
C.

Personal data of a group of individuals is erroneously sent to the wrong mailing list

C.

Personal data of a group of individuals is erroneously sent to the wrong mailing list

Answers
D.

A hacker publishes usernames, phone numbers and purchase history online after a cyber-attack

D.

A hacker publishes usernames, phone numbers and purchase history online after a cyber-attack

Answers
Suggested answer: A

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.

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

Total 180 questions
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