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

A.

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

A.

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

Answers
B.

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

B.

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

Answers
C.

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

C.

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

Answers
D.

Benchmarking the two Companies privacy policies against one another.

D.

Benchmarking the two Companies privacy policies against one another.

Answers
Suggested answer: B

Explanation:

When conducting due diligence during an acquisition, a privacy professional should avoid allowing legal in both companies to handle the privacy laws and compliance. This is because privacy is not only a legal issue, but also a business, technical, and operational issue that requires cross-functional collaboration and expertise. A privacy professional should be involved in the due diligence process to assess the privacy risks and opportunities of the acquisition, such as the type and scope of data processing, the data protection policies and practices, the data transfer mechanisms and agreements, the data breach history and response plans, and the impacts on the data processing operations post-acquisition. A privacy professional should also benchmark the two companies' privacy policies against one another to identify any gaps or inconsistencies that need to be addressed before or after the acquisition, .Reference:[CIPM - International Association of Privacy Professionals], [Free CIPM Study Guide - International Association of Privacy Professionals]

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?

A.

Internal unique personal identifiers.

A.

Internal unique personal identifiers.

Answers
B.

Plain text personal identifiers.

B.

Plain text personal identifiers.

Answers
C.

Hashed mobile identifiers.

C.

Hashed mobile identifiers.

Answers
D.

No personal identifiers.

D.

No personal identifiers.

Answers
Suggested answer: B

Explanation:

An online retailer detects an incident involving customer shopping history but no keys have been compromised. The Privacy Office is most concerned when it also involves plain text personal identifiers. Plain text personal identifiers are data elements that can directly identify an individual, such as name, email address, phone number, or social security number. Plain text means that the data is not encrypted or otherwise protected from unauthorized access or disclosure. If an incident involves plain text personal identifiers, it poses a high risk to the privacy and security of the customers, as their personal data could be exposed, stolen, misused, or manipulated by malicious actors. The Privacy Office should take immediate steps to contain, assess, notify, evaluate, and prevent such incidents, .Reference:[CIPM - International Association of Privacy Professionals], [Free CIPM Study Guide - International Association of Privacy Professionals]

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 for your vendor to be clear about the Society's breach notification expectations?

A.

Include notification provisions in the vendor contract

A.

Include notification provisions in the vendor contract

Answers
B.

Arrange regular telephone check-ins reviewing expectations

B.

Arrange regular telephone check-ins reviewing expectations

Answers
C.

Send a memorandum of understanding on breach notification

C.

Send a memorandum of understanding on breach notification

Answers
D.

Email the regulations that require breach notifications

D.

Email the regulations that require breach notifications

Answers
Suggested answer: A

Explanation:

This answer is the best way for Albert's vendor to be clear about the Society's breach notification expectations, as it can establish clear and binding terms and conditions for both parties regarding their roles and responsibilities for handling any data security incidents or breaches. Including notification provisions in the vendor contract can help to define what constitutes a breach, how it should be detected, reported and investigated, what information should be provided to the organization and within what time frame, what actions should be taken to mitigate or resolve the breach, and what consequences or liabilities may arise from the breach. The contract can also specify that the vendor must cooperate and coordinate with the organization in any breach notification activities to the relevant authorities, customers, partners or stakeholders.

What is the function of the privacy operational life cycle?

A.

It establishes initial plans for privacy protection and implementation

A.

It establishes initial plans for privacy protection and implementation

Answers
B.

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

B.

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

Answers
C.

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

C.

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

Answers
D.

It allows privacy policies to mature to a fixed form

D.

It allows privacy policies to mature to a fixed form

Answers
Suggested answer: B

Explanation:

The privacy operational life cycle is a process that allows the organization to respond to ever-changing privacy demands by continuously monitoring and improving the privacy program. It consists of four phases: assess, protect, sustain, and respond. Each phase involves different activities and outputs that help the organization identify and manage privacy risks and opportunities.Reference:IAPP CIPM Study Guide, page 14.

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

A.

As an industry benchmark that can apply to many organizations

A.

As an industry benchmark that can apply to many organizations

Answers
B.

As a fixed structure that directs changes in the organization

B.

As a fixed structure that directs changes in the organization

Answers
C.

As an aspirational goal that improves the organization

C.

As an aspirational goal that improves the organization

Answers
D.

As a living structure that aligns to changes in the organization

D.

As a living structure that aligns to changes in the organization

Answers
Suggested answer: D

Explanation:

The best way to view an organization's privacy framework is as a living structure that aligns to changes in the organization, such as business goals, stakeholder expectations, legal requirements, and technological developments. A privacy framework should be flexible and adaptable to support the organization's privacy strategy and vision. It should also be compatible with other frameworks, such as the cybersecurity framework, that the organization may use.Reference:IAPP CIPM Study Guide, page 16.

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

A.

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

A.

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

Answers
B.

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.

B.

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.

Answers
C.

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.

C.

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.

Answers
D.

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.

D.

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.

Answers
Suggested answer: C

Explanation:

An organization's mission statement for its privacy program should be concise, clear, and realistic. It should communicate the purpose and scope of the program, as well as the values and principles that guide it. It should also reflect the organization's culture and identity, and align with its strategic objectives. Out of the four options, statement C is the best one to use because it expresses the goal of protecting the privacy of all individuals who support the organization, and acknowledges the need to comply with all applicable privacy laws. The other statements are either too vague, too specific, too ambitious, or too irrelevant for a mission statement.Reference:IAPP CIPM Study Guide, page 18.

SCENARIO

Please 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?

A.

The nature of the data elements impacted

A.

The nature of the data elements impacted

Answers
B.

The likelihood the incident may lead to harm

B.

The likelihood the incident may lead to harm

Answers
C.

The likelihood that the information is accessible and usable

C.

The likelihood that the information is accessible and usable

Answers
D.

The number of individuals whose information was affected

D.

The number of individuals whose information was affected

Answers
Suggested answer: D

Explanation:

This answer is the only element of the incident that you adequately determined, as you knew exactly how many people were impacted by the vendor's data loss and you communicated this number to them in the notification. The other elements of the incident were not adequately determined, as you did not:

Assess the nature of the data elements impacted, such as what type, category, sensitivity or value of data was involved, and how it could affect the individuals' privacy, security or identity.

Evaluate the likelihood that the incident may lead to harm, such as financial, reputational, emotional or physical harm to the individuals or the organization, and how severe or widespread the harm could be.

Estimate the likelihood that the information is accessible and usable, such as who may have access to or control over the data, and how they may use or misuse it for malicious or fraudulent purposes.

SCENARIO

Please 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?

A.

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

A.

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

Answers
B.

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

B.

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

Answers
C.

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

C.

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

Answers
D.

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

D.

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

Answers
Suggested answer: B

Explanation:

This answer is the greatest concern regarding the notification, as it violates the data minimization principle and exposes the affected individuals to further privacy and security risks. Collecting more personally identifiable information than necessary to provide updates to the affected individuals means that the company is asking for their name, email address, and month and year of birth, which may not be relevant or proportionate for the purpose of sending email notifications. Collecting more information than necessary can also increase the likelihood of data breaches, identity theft, fraud, or misuse of the data by unauthorized or malicious parties.

SCENARIO

Please 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?

A.

You convened it to diffuse blame

A.

You convened it to diffuse blame

Answers
B.

The council has an overabundance of attorneys

B.

The council has an overabundance of attorneys

Answers
C.

It takes eight hours of emails to come to a decision

C.

It takes eight hours of emails to come to a decision

Answers
D.

The leader just joined the company as a consultant

D.

The leader just joined the company as a consultant

Answers
Suggested answer: C

Explanation:

This answer is the most concerning limitation of the incident-response council, as it indicates a lack of efficiency, urgency and coordination in handling the incident. It takes eight hours of emails to come to a decision means that the council is wasting valuable time and resources in communicating and resolving the incident, which may result in delayed or inadequate actions, increased harm or impact to the affected individuals or the organization, or non-compliance with any legal or contractual obligations or deadlines.

SCENARIO

Please 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?

A.

The vendor's representative does not have enough experience

A.

The vendor's representative does not have enough experience

Answers
B.

Signing a contract with CRUDLOK which lasts longer than one year

B.

Signing a contract with CRUDLOK which lasts longer than one year

Answers
C.

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

C.

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

Answers
D.

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

D.

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

Answers
Suggested answer: C

Explanation:

This answer is the greatest concern regarding the credit monitoring, as it may compromise the accuracy and effectiveness of the service, as well as expose the affected individuals to further privacy and security risks. The company did not collect enough identifiers to monitor one's credit means that the company only asked for the first name and the last-4 of their national identifier from the enrollees, which may not be sufficient or unique to identify and verify their identity and credit history. This may lead to errors, disputes or inaccuracies in the credit monitoring service, as well as potential identity theft, fraud or misuse of the data by unauthorized or malicious parties.

Total 180 questions
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