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SCENARIO

Please use the following to answer the next QUESTION:

As the Director of data protection for Consolidated Records Corporation, you are justifiably pleased with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of relatively minor data breaches that could easily have been worse. However, you have not had a reportable incident for the three years that you have been with the company. In fact, you consider your program a model that others in the data storage industry may note in their own program development.

You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward coherence across departments and throughout operations. You were aided along the way by the program's sponsor, the vice president of operations, as well as by a Privacy Team that started from a clear understanding of the need for change.

Initially, your work was greeted with little confidence or enthusiasm by the company's 'old guard' among both the executive team and frontline personnel working with data and interfacing with clients. Through the use of metrics that showed the costs not only of the breaches that had occurred, but also projections of the costs that easily could occur given the current state of operations, you soon had the leaders and key decision-makers largely on your side. Many of the other employees were more resistant, but face-to-face meetings with each department and the development of a baseline privacy training program achieved sufficient 'buy-in' to begin putting the proper procedures into place.

Now, privacy protection is an accepted component of all current operations involving personal or protected data and must be part of the end product of any process of technological development. While your approach is not systematic, it is fairly effective.

You are left contemplating:

What must be done to maintain the program and develop it beyond just a data breach prevention program? How can you build on your success?

What are the next action steps?

What process could most effectively be used to add privacy protections to a new, comprehensive program being developed at Consolidated?

A.

Privacy by Design.

A.

Privacy by Design.

Answers
B.

Privacy Step Assessment.

B.

Privacy Step Assessment.

Answers
C.

Information Security Planning.

C.

Information Security Planning.

Answers
D.

Innovation Privacy Standards.

D.

Innovation Privacy Standards.

Answers
Suggested answer: A

Explanation:

This is a process that embeds privacy protections into the design and development of new technologies, systems, products or services that involve personal data. It ensures that privacy is considered at every stage of the development process, from conception to completion, and that the privacy principles are integrated into the core functionality of the program.

Which of the following indicates you have developed the right privacy framework for your organization?

A.

It includes a privacy assessment of each major system.

A.

It includes a privacy assessment of each major system.

Answers
B.

It improves the consistency of the privacy program.

B.

It improves the consistency of the privacy program.

Answers
C.

It works at a different type of organization.

C.

It works at a different type of organization.

Answers
D.

It identifies all key stakeholders by name.

D.

It identifies all key stakeholders by name.

Answers
Suggested answer: B

Explanation:

Developing the right privacy framework for your organization means that you have a clear and coherent set of policies, procedures, and practices that align with your privacy objectives and obligations. A good privacy framework should improve the consistency of the privacy program by ensuring that all relevant stakeholders understand and follow the same standards and expectations across different functions, processes, and systems. A consistent privacy program can also help reduce errors, risks, and costs associated with privacy compliance.

Rationalizing requirements in order to comply with the various privacy requirements required by applicable law and regulation does NOT include which of the following?

A.

Harmonizing shared obligations and privacy rights across varying legislation and/or regulators.

A.

Harmonizing shared obligations and privacy rights across varying legislation and/or regulators.

Answers
B.

Implementing a solution that significantly addresses shared obligations and privacy rights.

B.

Implementing a solution that significantly addresses shared obligations and privacy rights.

Answers
C.

Applying the strictest standard for obligations and privacy rights that doesn't violate privacy laws elsewhere.

C.

Applying the strictest standard for obligations and privacy rights that doesn't violate privacy laws elsewhere.

Answers
D.

Addressing requirements that fall outside the common obligations and rights (outliers) on a case-by-case basis.

D.

Addressing requirements that fall outside the common obligations and rights (outliers) on a case-by-case basis.

Answers
Suggested answer: C

Explanation:

Rationalizing requirements in order to comply with the various privacy requirements required by applicable law and regulation means that you have a systematic and logical approach to harmonize and streamline your compliance efforts. Rationalizing requirements does include harmonizing shared obligations and privacy rights across varying legislation and/or regulators, implementing a solution that significantly addresses shared obligations and privacy rights, and addressing requirements that fall outside the common obligations and rights (outliers) on a case-by-case basis. These steps can help you avoid duplication, inconsistency, or inefficiency in your compliance activities.

What is the name for the privacy strategy model that describes delegated decision making?

A.

De-centralized.

A.

De-centralized.

Answers
B.

De-functionalized.

B.

De-functionalized.

Answers
C.

Hybrid.

C.

Hybrid.

Answers
D.

Matrix.

D.

Matrix.

Answers
Suggested answer: D

Explanation:

A matrix is a type of organizational structure that involves delegated decision making. In a matrix structure, employees report to more than one manager or leader, usually based on different functions or projects. For example, a software developer may report to both a product manager and a technical manager. A matrix structure allows for more flexibility, collaboration, and innovation in complex and dynamic environments.

The other options are not examples of delegated decision making structures. A de-centralized structure involves distributing decision making authority across different levels or units of the organization, rather than concentrating it at the top. A de-functionalized structure involves breaking down functional silos and creating cross-functional teams or processes. A hybrid structure involves combining elements of different types of structures, such as functional, divisional, or matrix.

Which of the following controls does the PCI DSS framework NOT require?

A.

Implement strong asset control protocols.

A.

Implement strong asset control protocols.

Answers
B.

Implement strong access control measures.

B.

Implement strong access control measures.

Answers
C.

Maintain an information security policy.

C.

Maintain an information security policy.

Answers
D.

Maintain a vulnerability management program.

D.

Maintain a vulnerability management program.

Answers
Suggested answer: A

Explanation:

The PCI DSS framework does not require implementing strong asset control protocols. Asset control protocols are policies and procedures that govern how an organization manages its physical and digital assets, such as inventory, equipment, software, data, etc. Asset control protocols may include aspects such as identification, classification, valuation, tracking, maintenance, disposal, etc. Asset control protocols are important for ensuring the security and integrity of an organization's assets, but they are not part of the PCI DSS framework.

Which of the following privacy frameworks are legally binding?

A.

Binding Corporate Rules (BCRs).

A.

Binding Corporate Rules (BCRs).

Answers
B.

Generally Accepted Privacy Principles (GAPP).

B.

Generally Accepted Privacy Principles (GAPP).

Answers
C.

Asia-Pacific Economic Cooperation (APEC) Privacy Framework.

C.

Asia-Pacific Economic Cooperation (APEC) Privacy Framework.

Answers
D.

Organization for Economic Co-Operation and Development (OECD) Guidelines.

D.

Organization for Economic Co-Operation and Development (OECD) Guidelines.

Answers
Suggested answer: A

Explanation:

Binding Corporate Rules (BCRs) are a set of legally binding rules that allow multinational corporations or groups of companies to transfer personal data across borders within their organization in compliance with the EU data protection law1BCRs are approved by the competent data protection authorities in the EU and are enforceable by data subjects and the authorities2BCRs are one of the mechanisms recognized by the EU General Data Protection Regulation (GDPR) to ensure an adequate level of protection for personal data transferred outside the European Economic Area (EEA)3

Your marketing team wants to know why they need a check box for their SMS opt-in. You explain it is part of the consumer's right to?

A.

Request correction.

A.

Request correction.

Answers
B.

Raise complaints.

B.

Raise complaints.

Answers
C.

Have access.

C.

Have access.

Answers
D.

Be informed.

D.

Be informed.

Answers
Suggested answer: D

Explanation:

The marketing team needs a check box for their SMS opt-in because it is part of the consumer's right to be informed. This right means that consumers have the right to know how their personal data is collected, used, shared, and protected by the organization. The check box allows consumers to give their consent and opt-in to receive SMS messages from the organization, and also informs them of the purpose and scope of such messages. The other rights are not relevant in this case, as they are related to other aspects of data processing, such as correction, complaints, and access.Reference:CIPM Body of Knowledge, Domain IV: Privacy Program Communication, Section A: Communicating to Stakeholders, Subsection 1: Consumer Rights.

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 legal teams may not have the expertise or the resources to address all the privacy issues and risks that may arise from the acquisition. A privacy professional should be involved in the due diligence process to ensure that the privacy policies, practices, and obligations of both companies are aligned and compliant with the applicable laws and regulations. The other options are not things that a privacy professional should avoid, but rather things that they should do as part of the due diligence process.Reference:CIPM Body of Knowledge, Domain V: Privacy Program Management, Section A: Privacy Program Administration, Subsection 3: Due Diligence.

SCENARIO

Please use the following to answer the next question

You were recently hired by InStyte Date Corp as a privacy manager to help InStyle Data Corp become compliant with a new data protection law

The law mandates that businesses have reasonable and appropriate security measures in place to protect personal data. Violations of that mandate are heavily fined and the legislators have stated that they will aggressively pursue companies that don t comply with the new law

You are paved with a security manager and tasked with reviewing InStyle Data Corp s current state and advising the business how it can meet the 'reasonable and appropriate security' requirement InStyle Data Corp has grown rapidly and has not kept a data inventory or completed a data mapping InStyte Data Corp has also developed security-related policies ad hoc and many have never been implemented The various teams involved in the creation and testing of InStyle Data Corp s products experience significant turnover and do not have well defined roles There's little documentation addressing what personal data is processed by which product and for what purpose

Work needs to begin on this project immediately so that InStyle Data Corp can become compliant by the time the law goes into effect. You and you partner discover that InStyle Data Corp regularly sends files containing sensitive personal data back to its customers through email sometimes using InStyle Data Corp employees personal email accounts. You also team that InStyle Data Corp s privacy and information security teams are not informed of new personal data flows, new products developed by InStyte Data Corp that process personal data, or updates to existing InStyle Data Corp products that may change what or how the personal data is processed until after the product or update has gone have.

Through a review of InStyle Date Corp's test and development environment logs, you discover InStyle Data Corp sometimes gives login credentials to any InStyle Data Corp employee or contractor who requests them. The test environment only contains dummy data but the development environment contains personal data including Social Security Numbers, hearth ^formation and financial information All credentialed InStyle Data Corp employees and contractors have the ability to after and delete personal data in both environments regardless of their role or what project they are working on.

You and your partner provide a gap assessment citing the issues you spotted, along with recommended remedial actions and a method to measure implementation InStyle Data Corp implements all of the recommended security controls You review the processes roles, controls and measures taken to appropriately protect the personal data at every stop However, you realize there is no plan for monitoring and nothing in place addressing sanctions for violations of the updated policies and procedures InStyle Data Corp pushes back, stating they do not have the resources for such monitoring.

What aspect of the data management life cycle will still be unaddressed it you cannot find the resources to become compliant?

A.

Auditability.

A.

Auditability.

Answers
B.

Enforcement

B.

Enforcement

Answers
C.

Irretrievability

C.

Irretrievability

Answers
D.

Access management

D.

Access management

Answers
Suggested answer: B

Explanation:

The aspect of the data management life cycle that will still be unaddressed if you cannot find the resources to become compliant is enforcement. Enforcement means ensuring that the data policies and procedures are followed by all data users and stakeholders, and that any violations or deviations are detected, reported, and corrected. Enforcement also involves imposing sanctions or penalties for non-compliance, such as revoking access rights, issuing warnings, or terminating contracts. Without enforcement, the data security measures that you implemented may not be effective or sustainable, as there would be no accountability or deterrence for data misuse or abuse1, 2.

To address the enforcement aspect of the data management life cycle, you should try to convince InStyle Data Corp of the importance and benefits of monitoring and sanctioning data activities. You should explain that monitoring can help identify and prevent data breaches, errors, or inefficiencies, as well as demonstrate compliance with the new data protection law. You should also explain that sanctioning can help enforce data discipline and responsibility, as well as deter potential violators or malicious actors. You should also propose some possible ways to allocate or optimize the resources for monitoring and sanctioning, such as automating some processes, outsourcing some tasks, or prioritizing some data types or sources1, 2.

SCENARIO

Please use the following to answer the next question

You were recently hired by InStyte Date Corp as a privacy manager to help InStyle Data Corp become compliant with a new data protection law

The law mandates that businesses have reasonable and appropriate security measures in place to protect personal data. Violations of that mandate are heavily fined and the legislators have stated that they will aggressively pursue companies that don t comply with the new law

You are paved with a security manager and tasked with reviewing InStyle Data Corp s current state and advising the business how it can meet the 'reasonable and appropriate security' requirement InStyle Data Corp has grown rapidly and has not kept a data inventory or completed a data mapping InStyte Data Corp has also developed security-related policies ad hoc and many have never been implemented The various teams involved in the creation and testing of InStyle Data Corp s products experience significant turnover and do not have well defined roles There's little documentation addressing what personal data is processed by which product and for what purpose

Work needs to begin on this project immediately so that InStyle Data Corp can become compliant by the time the law goes into effect. You and you partner discover that InStyle Data Corp regularly sends files containing sensitive personal data back to its customers through email sometimes using InStyle Data Corp employees personal email accounts. You also team that InStyle Data Corp s privacy and information security teams are not informed of new personal data flows, new products developed by InStyte Data Corp that process personal data, or updates to existing InStyle Data Corp products that may change what or how the personal data is processed until after the product or update has gone have.

Through a review of InStyle Date Corp's test and development environment logs, you discover InStyle Data Corp sometimes gives login credentials to any InStyle Data Corp employee or contractor who requests them. The test environment only contains dummy data but the development environment contains personal data including Social Security Numbers, hearth ^formation and financial information All credentialed InStyle Data Corp employees and contractors have the ability to after and delete personal data in both environments regardless of their role or what project they are working on.

You and your partner provide a gap assessment citing the issues you spotted, along with recommended remedial actions and a method to measure implementation InStyle Data Corp implements all of the recommended security controls You review the processes roles, controls and measures taken to appropriately protect the personal data at every stop However, you realize there is no plan for monitoring and nothing in place addressing sanctions for violations of the updated policies and procedures InStyle Data Corp pushes back, stating they do not have the resources for such monitoring.

Having completed the gap assessment, you and your partner need to first undertake a thorough review of?

A.

Data life cyde

A.

Data life cyde

Answers
B.

Security policies.

B.

Security policies.

Answers
C.

System development life cycle.

C.

System development life cycle.

Answers
D.

Privacy Impact (PIA).

D.

Privacy Impact (PIA).

Answers
Suggested answer: C

Explanation:

Having completed the gap assessment, you and your partner need to first undertake a thorough review of the system development life cycle (SDLC). This is because the SDLC is the process of creating, testing, deploying, and maintaining software products, which involves the processing of personal data by InStyle Data Corp. A review of the SDLC will help you identify and address the privacy and security risks and requirements at each stage of the development process, such as design, coding, testing, and deployment. The other options are not the first things that you need to review, as they are either part of the gap assessment (security policies) or the outcome of the review (data life cycle and privacy impact assessment).


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