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

A.

Rationale for the policy.

A.

Rationale for the policy.

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B.

Points of contact for the employee.

B.

Points of contact for the employee.

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C.

Roles and responsibilities of the different groups of individuals.

C.

Roles and responsibilities of the different groups of individuals.

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D.

Explanation of how the policy is applied within the organization.

D.

Explanation of how the policy is applied within the organization.

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Suggested answer: A

Explanation:

When devising effective employee policies to address a particular issue, it is important to include the rationale for the policy in the first draft, as it explains why the policy is needed and what benefits it brings to the organization and its employees. The rationale can also help to gain support and buy-in from the management and staff, as well as to align the policy with the organizational values and goals. The other options are also important elements of an employee policy, but they can be added or refined in later drafts.Reference:CIPM Body of Knowledge, Domain IV: Privacy Program Communication Activities, Task 2: Develop internal communication plans.

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.

A Record of Authority.

A.

A Record of Authority.

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B.

A Personal Data Inventory.

B.

A Personal Data Inventory.

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C.

A Privacy Threshold Analysis (PTA).

C.

A Privacy Threshold Analysis (PTA).

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D.

A Privacy Impact Assessment (PIA).

D.

A Privacy Impact Assessment (PIA).

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Suggested answer: D

Explanation:

A Privacy Impact Assessment (PIA) is a process that helps an organization identify and evaluate the potential privacy risks and impacts of a new or existing project, program, system, or service that involves the collection, use, disclosure, or retention of personal information. A PIA also helps an organization identify and implement appropriate measures to mitigate or eliminate those risks and impacts, and ensure compliance with applicable privacy laws, regulations, and standards. A PIA should be completed to effectively make changes that involve customer personal information, such as converting paper records into electronic form, uploading the records into a new third-party marketing tool, and merging the customer personal information in the marketing tool with information from other applications. A PIA can help an organization assess the necessity, proportionality, and legality of the proposed changes, as well as the potential privacy risks to the customers and the organization, such as unauthorized access, disclosure, modification, or loss of personal information, identity theft, fraud, reputational damage, or legal liability. A PIA can also help an organization implement appropriate measures to mitigate or eliminate those risks, such as data minimization, encryption, anonymization, pseudonymization, consent management, access control, security safeguards, contractual clauses, data protection impact assessments (DPIAs), data subject rights, breach notification procedures, and privacy policies.

CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section C: Monitoring and Managing Program Performance Subsection 1: Privacy Impact Assessments1

CIPM Study Guide (2021), Chapter 9: Monitoring and Managing Program Performance Section 9.1: Privacy Impact Assessments2

CIPM Textbook (2019), Chapter 9: Monitoring and Managing Program Performance Section 9.1: Privacy Impact Assessments3

CIPM Practice Exam (2021), Question 1464

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

A.

Processing on a large scale of special categories of data.

A.

Processing on a large scale of special categories of data.

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B.

Monitoring of a publicly accessible area on a large scale.

B.

Monitoring of a publicly accessible area on a large scale.

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C.

Assessment of the necessity and proportionality.

C.

Assessment of the necessity and proportionality.

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D.

Assessment of security measures.

D.

Assessment of security measures.

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Suggested answer: A

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.

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

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

A.

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

A.

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

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B.

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

B.

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

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C.

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

C.

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

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D.

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

D.

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

Answers
Suggested answer: D

Explanation:

The information technology (IT) group supporting and enhancing the privacy program and privacy policy by developing processes and controls best supports implementing controls to bring privacy policies into effect. Privacy policies are documents that define the organization's principles, commitments, and practices for collecting, using, disclosing, retaining, and protecting personal information. Privacy policies need to be translated into operational processes and controls that ensure compliance with the policy objectives and requirements. The IT group can support and enhance the privacy program and privacy policy by developing processes and controls such as: data classification, data inventory, data mapping, data minimization, consent management, access control, encryption, pseudonymization, anonymization, security safeguards, breach detection and response, data subject rights fulfillment, data retention and disposal, audit logging and monitoring, privacy by design and default, privacy impact assessments, privacy notices and statements, privacy training and awareness.

CIPM Body of Knowledge (2021), Domain II: Privacy Program Framework, Section A: Privacy Program Framework Components Subsection 1: Privacy Policies

CIPM Study Guide (2021), Chapter 4: Privacy Program Framework Components Section 4.1: Privacy Policies

CIPM Textbook (2019), Chapter 4: Privacy Program Framework Components Section 4.1: Privacy Policies

CIPM Practice Exam (2021), Question 148

What is most critical when outsourcing data destruction service?

A.

Obtain a certificate of data destruction.

A.

Obtain a certificate of data destruction.

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B.

Confirm data destruction must be done on-site.

B.

Confirm data destruction must be done on-site.

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C.

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

C.

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

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D.

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

D.

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

Answers
Suggested answer: A

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.

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

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

A.

Data destruction triggers and methods should be documented.

A.

Data destruction triggers and methods should be documented.

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B.

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

B.

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

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C.

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

C.

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

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D.

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

D.

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

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Suggested answer: C

Explanation:

Documentation related to audit controls (third-party or internal) should be saved in apermanentformat by default, not a non-permanent one. This is to ensure that the organization can demonstrate its compliance with the applicable laws and regulations, as well as its own policies and procedures, in case of an audit or a legal challenge. The other options are valid requirements for data retention and destruction policies, as they help to minimize the risks and costs associated with storing personal information beyond its intended purpose.Reference:CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 3: Manage data retention and disposal.

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

A.

Reducing storage costs.

A.

Reducing storage costs.

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B.

Ensuring data is kept for no longer than necessary.

B.

Ensuring data is kept for no longer than necessary.

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C.

Crafting policies which ensure minimal data is collected.

C.

Crafting policies which ensure minimal data is collected.

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D.

Increasing awareness of the importance of confidentiality.

D.

Increasing awareness of the importance of confidentiality.

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Suggested answer: C

Explanation:

Crafting policies which ensure minimal data is collected is least likely to be achieved by implementing a Data Lifecycle Management (DLM) program, as it is more related to the data collection stage, not the data management stage. A DLM program focuses on how to handle the data after it has been collected, such as how to store, use, share, and dispose of it. The other options are more likely to be achieved by implementing a DLM program, as they help to optimize the data storage costs, comply with the data retention obligations, and protect the data confidentiality.Reference:CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 1: Manage data inventory.

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'?

A.

Evaluating operations, systems, and processes.

A.

Evaluating operations, systems, and processes.

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B.

Tracking, reporting and documenting complaints from all sources.

B.

Tracking, reporting and documenting complaints from all sources.

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C.

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

C.

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

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D.

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

D.

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

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Suggested answer: A

Explanation:

Evaluating operations, systems, and processes is best described as 'auditing', as it involves conducting a systematic and independent examination of the organization's privacy practices and controls to verify their effectiveness and compliance. The other options are more related to other forms of monitoring, such as complaint handling, reporting, and third-party oversight.Reference:CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 5: Monitor privacy program performance.

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

A.

Running vulnerability scanning tools.

A.

Running vulnerability scanning tools.

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B.

Reviewing your privacy program metrics.

B.

Reviewing your privacy program metrics.

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C.

Reviewing your role-based access controls.

C.

Reviewing your role-based access controls.

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D.

Establishing a complaint-monitoring process.

D.

Establishing a complaint-monitoring process.

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Suggested answer: A

Explanation:

Running vulnerability scanning tools will best assist you in quickly identifying weaknesses in your network and storage, as they can detect and report any potential security flaws or gaps that could compromise your data protection. The other options are also useful for enhancing your privacy program, but they are not directly related to identifying weaknesses in your network and storage.Reference:CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 2: Manage data security.

Which of the following is NOT a type of privacy program metric?

A.

Business enablement metrics.

A.

Business enablement metrics.

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B.

Data enhancement metrics.

B.

Data enhancement metrics.

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C.

Value creation metrics.

C.

Value creation metrics.

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D.

Risk-reduction metrics.

D.

Risk-reduction metrics.

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Suggested answer: B

Explanation:

Data enhancement metrics are not a type of privacy program metric because they do not measure the performance, value, or risk of the privacy program. Data enhancement metrics are related to the quality, accuracy, and completeness of the data collected and processed by the organization, which are not directly linked to the privacy program objectives.Reference:CIPM Body of Knowledge, Domain II: Privacy Program Governance, Section B: Establishing a Privacy Program Framework, Subsection 2: Privacy Program Metrics.

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