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An executive for a multinational online retail company in the United States is looking for guidance in developing her company's privacy program beyond what is specifically required by law.

What would be the most effective resource for the executive to consult?

A.

Internal auditors.

A.

Internal auditors.

Answers
B.

Industry frameworks.

B.

Industry frameworks.

Answers
C.

Oversight organizations.

C.

Oversight organizations.

Answers
D.

Breach notifications from competitors.

D.

Breach notifications from competitors.

Answers
Suggested answer: B

Explanation:

Industry frameworks are the most effective resource for an executive who wants to develop her company's privacy program beyond what is specifically required by law. Industry frameworks are collections of best practices, standards, and guidelines that help organizations establish and improve their privacy policies and procedures. Industry frameworks can help organizations demonstrate their commitment to privacy, enhance their reputation and trustworthiness, and comply with multiple privacy regulations.Some examples of industry frameworks are the NIST Privacy Framework2, the ISO 27701 Privacy Information Management System3, and the AICPA/CICA Generally Accepted Privacy Principles (GAPP)4. The other options are not as effective as industry frameworks for developing a privacy program. Internal auditors can help evaluate the effectiveness and compliance of existing privacy controls, but they may not provide guidance on how to improve or expand them. Oversight organizations can enforce privacy laws and regulations, but they may not offer advice on how to go beyond the legal requirements. Breach notifications from competitors can alert organizations to potential threats and vulnerabilities, but they may not suggest how to prevent or mitigate them.Reference:NIST Privacy Framework;ISO 27701 Privacy Information Management System;AICPA/CICA Generally Accepted Privacy Principles (GAPP)

What is one reason the European Union has enacted more comprehensive privacy laws than the United States?

A.

To ensure adequate enforcement of existing laws.

A.

To ensure adequate enforcement of existing laws.

Answers
B.

To ensure there is adequate funding for enforcement.

B.

To ensure there is adequate funding for enforcement.

Answers
C.

To allow separate industries to set privacy standards.

C.

To allow separate industries to set privacy standards.

Answers
D.

To allow the free movement of data between member countries.

D.

To allow the free movement of data between member countries.

Answers
Suggested answer: D

Explanation:

One reason the European Union has enacted more comprehensive privacy laws than the United States is to allow the free movement of data between member countries. The EU considers data protection as a fundamental right that applies to all individuals within its territory, regardless of their nationality or residence.The EU has adopted a harmonized legal framework for data protection, such as the GDPR1and the ePrivacy Directive5, that applies to all member states and ensures a consistent level of protection across the EU. The EU also requires that any transfers of personal data outside the EU are subject to adequate safeguards or exceptions that guarantee an equivalent level of protection. The EU's approach to data protection aims to facilitate the internal market and promote economic and social integration among member states by removing barriers and restrictions to the cross-border flow of data. The other options are not reasons why the EU has enacted more comprehensive privacy laws than the US. The EU does not necessarily have more adequate enforcement or funding for its privacy laws than the US, although it does have a network of independent supervisory authorities that monitor and enforce compliance with the EU data protection rules. The EU does not allow separate industries to set privacy standards, but rather imposes uniform and binding rules for all sectors and activities that involve personal data processing.Reference:GDPR;ePrivacy Directive

All of the following changes will likely trigger a data inventory update EXCEPT?

A.

Outsourcing the Customer Relationship Management (CRM) function.

A.

Outsourcing the Customer Relationship Management (CRM) function.

Answers
B.

Acquisition of a new subsidiary.

B.

Acquisition of a new subsidiary.

Answers
C.

Onboarding of a new vendor.

C.

Onboarding of a new vendor.

Answers
D.

Passage of a new privacy regulation.

D.

Passage of a new privacy regulation.

Answers
Suggested answer: D

Explanation:

All of the changes listed will likely trigger a data inventory update except for the passage of a new privacy regulation. A data inventory is a record of all personal data that an organization collects, processes, stores, shares, or disposes of. A data inventory helps an organization understand what types of personal data it holds, where it comes from, where it goes, and how it is protected. A data inventory should be updated regularly to reflect any changes in the organization's data processing activities or practices. Some examples of changes that would trigger a data inventory update are outsourcing a business function, acquiring a new subsidiary, or onboarding a new vendor. These changes may involve new sources or destinations of personal data, new purposes or categories of processing, new security measures or risks, or new contractual agreements or obligations. The passage of a new privacy regulation may not trigger a data inventory update unless it affects the organization's existing data processing activities or practices. However, it may trigger a compliance assessment or gap analysis to determine if the organization needs to make any adjustments to its privacy program or policies to meet the new legal requirements.Reference:Data Inventory Hub;Data Inventory: What It Is & How To Create One

SCENARIO

Please use the following to answer the next QUESTION:

Paul Daniels, with years of experience as a CEO, is worried about his son Carlton's successful venture, Gadgo. A technological innovator in the communication industry that quickly became profitable, Gadgo has moved beyond its startup phase. While it has retained its vibrant energy, Paul fears that under Carlton's direction, the company may not be taking its risks or obligations as seriously as it needs to. Paul has hired you, a Privacy Consultant, to assess the company and report to both father and son. 'Carlton won't listen to me,' Paul says, 'but he may pay attention to an expert.'

Gadgo's workplace is a clubhouse for innovation, with games, toys, snacks. espresso machines, giant fish tanks and even an iguana who regards you with little interest. Carlton, too, seems bored as he describes to you the company's procedures and technologies for data protection. It's a loose assemblage of controls, lacking consistency and with plenty of weaknesses. 'This is a technology company,' Carlton says. 'We create. We innovate. I don't want unnecessary measures that will only slow people down and clutter their thoughts.'

The meeting lasts until early evening. Upon leaving, you walk through the office it looks as if a strong windstorm has recently blown through, with papers scattered across desks and tables and even the floor. A 'cleaning crew' of one teenager is emptying the trash bins. A few computers have been left on for the night, others are missing. Carlton takes note of your attention to this: 'Most of my people take their laptops home with them, or use their own tablets or phones. I want them to use whatever helps them to think and be ready day or night for that great insight. It may only come once!'

What would be the best kind of audit to recommend for Gadgo?

A.

A supplier audit.

A.

A supplier audit.

Answers
B.

An internal audit.

B.

An internal audit.

Answers
C.

A third-party audit.

C.

A third-party audit.

Answers
D.

A self-certification.

D.

A self-certification.

Answers
Suggested answer: C

Explanation:

This answer is the best kind of audit to recommend for Gadgo, as it can provide an independent and objective assessment of the company's privacy program and practices, as well as identify any gaps, weaknesses or risks that need to be addressed or improved. A third-party audit is conducted by an external auditor who has the necessary expertise, experience and credentials to evaluate the company's compliance with the applicable laws, regulations, standards and best practices for data protection.A third-party audit can also help to enhance the company's reputation and trust among its customers, partners and stakeholders, as well as demonstrate its commitment and accountability for privacy protection.Reference: IAPP CIPM Study Guide, page 881; ISO/IEC 27002:2013, section 18.2.1

SCENARIO

Please use the following to answer the next QUESTION:

Paul Daniels, with years of experience as a CEO, is worried about his son Carlton's successful venture, Gadgo. A technological innovator in the communication industry that quickly became profitable, Gadgo has moved beyond its startup phase. While it has retained its vibrant energy, Paul fears that under Carlton's direction, the company may not be taking its risks or obligations as seriously as it needs to. Paul has hired you, a Privacy Consultant, to assess the company and report to both father and son. 'Carlton won't listen to me,' Paul says, 'but he may pay attention to an expert.'

Gadgo's workplace is a clubhouse for innovation, with games, toys, snacks. espresso machines, giant fish tanks and even an iguana who regards you with little interest. Carlton, too, seems bored as he describes to you the company's procedures and technologies for data protection. It's a loose assemblage of controls, lacking consistency and with plenty of weaknesses. 'This is a technology company,' Carlton says. 'We create. We innovate. I don't want unnecessary measures that will only slow people down and clutter their thoughts.'

The meeting lasts until early evening. Upon leaving, you walk through the office it looks as if a strong windstorm has recently blown through, with papers scattered across desks and tables and even the floor. A 'cleaning crew' of one teenager is emptying the trash bins. A few computers have been left on for the night, others are missing. Carlton takes note of your attention to this: 'Most of my people take their laptops home with them, or use their own tablets or phones. I want them to use whatever helps them to think and be ready day or night for that great insight. It may only come once!'

What phase in the Privacy Maturity Model (PMM) does Gadgo's privacy program best exhibit?

A.

Ad hoc.

A.

Ad hoc.

Answers
B.

Defined.

B.

Defined.

Answers
C.

Repeatable.

C.

Repeatable.

Answers
D.

Managed.

D.

Managed.

Answers
Suggested answer: A

Explanation:

This answer is the best way to describe the phase in the Privacy Maturity Model (PMM) that Gadgo's privacy program best exhibits, as it shows that the company has no formal or consistent approach to privacy protection and that its privacy practices are largely reactive, unplanned and uncoordinated. The ad hoc phase is the lowest level of maturity in the PMM, which is a framework that measures the effectiveness and maturity of an organization's privacy program based on five phases: ad hoc, repeatable, defined, managed and optimized.The ad hoc phase indicates that the organization has little or no awareness of its privacy obligations and risks, and that its privacy activities are dependent on individual efforts or initiatives, rather than on organizational policies or processes.Reference: IAPP CIPM Study Guide, page 891; ISO/IEC 27002:2013, section 18.1.1

Incipia Corporation just trained the last of its 300 employees on their new privacy policies and procedures.

If Incipia wanted to analyze the effectiveness of the training over the next 6 months, which form of trend analysis should they use?

A.

Cyclical.

A.

Cyclical.

Answers
B.

Irregular.

B.

Irregular.

Answers
C.

Statistical.

C.

Statistical.

Answers
D.

Standard variance.

D.

Standard variance.

Answers
Suggested answer: C

Explanation:

This answer is the best form of trend analysis that Incipia Corporation should use to analyze the effectiveness of the training over the next six months, as it can provide a quantitative and objective way to measure and compare the results and outcomes of the training against predefined criteria or indicators. Statistical trend analysis is a method that involves collecting, analyzing and presenting data using statistical tools and techniques, such as charts, graphs, tables or formulas.Statistical trend analysis can help to identify patterns, changes or correlations in the data over time, as well as to evaluate the performance and impact of the training on the organization's privacy program and objectives.Reference: IAPP CIPM Study Guide, page 901; ISO/IEC 27002:2013, section 18.1.3

SCENARIO

Please use the following to answer the next QUESTION:

Ben works in the IT department of IgNight, Inc., a company that designs lighting solutions for its clients. Although IgNight's customer base consists primarily of offices in the US, some individuals have been so impressed by the unique aesthetic and energy-saving design of the light fixtures that they have requested

IgNight's installations in their homes across the globe.

One Sunday morning, while using his work laptop to purchase tickets for an upcoming music festival, Ben happens to notice some unusual user activity on company files. From a cursory review, all the data still appears to be where it is meant to be but he can't shake off the feeling that something is not right. He knows that it is a possibility that this could be a colleague performing unscheduled maintenance, but he recalls an email from his company's security team reminding employees to be on alert for attacks from a known group of malicious actors specifically targeting the industry.

Ben is a diligent employee and wants to make sure that he protects the company but he does not want to bother his hard-working colleagues on the weekend. He is going to discuss the matter with this manager first thing in the morning but wants to be prepared so he can demonstrate his knowledge in this area and plead his case for a promotion.

To determine the steps to follow, what would be the most appropriate internal guide for Ben to review?

A.

Incident Response Plan.

A.

Incident Response Plan.

Answers
B.

Code of Business Conduct.

B.

Code of Business Conduct.

Answers
C.

IT Systems and Operations Handbook.

C.

IT Systems and Operations Handbook.

Answers
D.

Business Continuity and Disaster Recovery Plan.

D.

Business Continuity and Disaster Recovery Plan.

Answers
Suggested answer: A

Explanation:

The most appropriate internal guide for Ben to review is the Incident Response Plan. An Incident Response Plan is a document that outlines how an organization will respond to a security incident, such as a data breach, a cyberattack, or a malware infection. An Incident Response Plan typically includes:

The roles and responsibilities of the incident response team and other stakeholders

The procedures and protocols for detecting, containing, analyzing, and resolving incidents

The communication and escalation channels for reporting and notifying incidents

The tools and resources for conducting incident response activities

The criteria and methods for evaluating and improving the incident response process

An Incident Response Plan helps an organization prepare for and deal with security incidents in an effective and efficient manner. It also helps an organization minimize the impact and damage of security incidents, comply with legal and regulatory obligations, and restore normal operations as soon as possible.

The other options are not as relevant or useful as the Incident Response Plan for Ben's situation. The Code of Business Conduct is a document that defines the ethical standards and expectations for the organization's employees and stakeholders. It may include some general principles or policies related to security, but it does not provide specific guidance on how to handle security incidents. The IT Systems and Operations Handbook is a document that describes the technical aspects and functions of the organization's IT systems and infrastructure. It may include some information on security controls and configurations, but it does not provide detailed instructions on how to perform incident response tasks. The Business Continuity and Disaster Recovery Plan is a document that outlines how an organization will continue its critical functions and operations in the event of a disruption or disaster, such as a natural disaster, a power outage, or a fire. It may include some measures to protect or recover data and systems, but it does not focus on security incidents or threats.Reference:What Is an Incident Response Plan for IT?;Incident Response Plan (IRP) Basics

SCENARIO

Please use the following to answer the next QUESTION:

Ben works in the IT department of IgNight, Inc., a company that designs lighting solutions for its clients. Although IgNight's customer base consists primarily of offices in the US, some individuals have been so impressed by the unique aesthetic and energy-saving design of the light fixtures that they have requested IgNight's installations in their homes across the globe.

One Sunday morning, while using his work laptop to purchase tickets for an upcoming music festival, Ben happens to notice some unusual user activity on company files. From a cursory review, all the data still appears to be where it is meant to be but he can't shake off the feeling that something is not right. He knows that it is a possibility that this could be a colleague performing unscheduled maintenance, but he recalls an email from his company's security team reminding employees to be on alert for attacks from a known group of malicious actors specifically targeting the industry.

Ben is a diligent employee and wants to make sure that he protects the company but he does not want to bother his hard-working colleagues on the weekend. He is going to discuss the matter with this manager first thing in the morning but wants to be prepared so he can demonstrate his knowledge in this area and plead his case for a promotion.

If this were a data breach, how is it likely to be categorized?

A.

Availability Breach.

A.

Availability Breach.

Answers
B.

Authenticity Breach.

B.

Authenticity Breach.

Answers
C.

Confidentiality Breach.

C.

Confidentiality Breach.

Answers
D.

Integrity Breach.

D.

Integrity Breach.

Answers
Suggested answer: C

Explanation:

If this were a data breach, it is likely to be categorized as a confidentiality breach. A confidentiality breach is a type of data breach that involves unauthorized or accidental disclosure of or access to personal data. A confidentiality breach violates the principle of confidentiality, which requires that personal data is protected from unauthorized or unlawful use or disclosure. A confidentiality breach can occur when personal data is exposed to unauthorized parties, such as hackers, competitors, or third parties without consent. A confidentiality breach can also occur when personal data is sent to incorrect recipients, such as by email or mail.

The other options are not likely to be the correct category for this data breach. An availability breach is a type of data breach that involves accidental or unauthorized loss of access to or destruction of personal data. An availability breach violates the principle of availability, which requires that personal data is accessible and usable by authorized parties when needed. An availability breach can occur when personal data is deleted, corrupted, encrypted, or otherwise rendered inaccessible by malicious actors or technical errors. An authenticity breach is a type of data breach that involves unauthorized or accidental alteration of personal data. An authenticity breach violates the principle of authenticity, which requires that personal data is accurate and up to date. An authenticity breach can occur when personal data is modified, tampered with, or falsified by malicious actors or human errors. An integrity breach is a type of data breach that involves unauthorized or accidental alteration of personal data that affects its quality or reliability. An integrity breach violates the principle of integrity, which requires that personal data is complete and consistent with its intended purpose. An integrity breach can occur when personal data is incomplete, inconsistent, outdated, or inaccurate due to malicious actors or human errors.Reference:Personal Data Breaches: A Guide;Guidance on the Categorisation and Notification of Personal Data Breaches

SCENARIO

Please use the following to answer the next QUESTION:

Ben works in the IT department of IgNight, Inc., a company that designs lighting solutions for its clients. Although IgNight's customer base consists primarily of offices in the US, some individuals have been so impressed by the unique aesthetic and energy-saving design of the light fixtures that they have requested IgNight's installations in their homes across the globe.

One Sunday morning, while using his work laptop to purchase tickets for an upcoming music festival, Ben happens to notice some unusual user activity on company files. From a cursory review, all the data still appears to be where it is meant to be but he can't shake off the feeling that something is not right. He knows that it is a possibility that this could be a colleague performing unscheduled maintenance, but he recalls an email from his company's security team reminding employees to be on alert for attacks from a known group of malicious actors specifically targeting the industry.

Ben is a diligent employee and wants to make sure that he protects the company but he does not want to bother his hard-working colleagues on the weekend. He is going to discuss the matter with this manager first thing in the morning but wants to be prepared so he can demonstrate his knowledge in this area and plead his case for a promotion.

Going forward, what is the best way for IgNight to prepare its IT team to manage these kind of security events?

A.

Tabletop exercises.

A.

Tabletop exercises.

Answers
B.

Update its data inventory.

B.

Update its data inventory.

Answers
C.

IT security awareness training.

C.

IT security awareness training.

Answers
D.

Share communications relating to scheduled maintenance.

D.

Share communications relating to scheduled maintenance.

Answers
Suggested answer: A

Explanation:

The best way for IgNight to prepare its IT team to manage these kind of security events is to conduct tabletop exercises. Tabletop exercises are simulated scenarios that test the organization's ability to respond to security incidents in a realistic and interactive way. Tabletop exercises typically involve:

A facilitator who guides the participants through the scenario and injects additional challenges or variables

A scenario that describes a plausible security incident based on real-world threats or past incidents

A set of objectives that define the expected outcomes and goals of the exercise

A set of questions that prompt the participants to discuss their roles, responsibilities, actions, decisions, and communications during the incident response process

A feedback mechanism that collects the participants' opinions and suggestions on how to improve the incident response plan and capabilities

Tabletop exercises help an organization prepare for and deal with security incidents by:

Enhancing the awareness and skills of the IT team and other stakeholders involved in incident response

Identifying and addressing the gaps, weaknesses, and challenges in the incident response plan and process

Improving the coordination and collaboration among the IT team and other stakeholders during incident response

Evaluating and validating the effectiveness and efficiency of the incident response plan and process

Generating and implementing lessons learned and best practices for incident response

The other options are not as effective or useful as tabletop exercises for preparing the IT team to manage security events. Updating the data inventory is a good practice for maintaining an accurate and comprehensive record of the personal data that the organization collects, processes, stores, shares, or disposes of. However, it does not test or improve the organization's incident response capabilities or readiness. IT security awareness training is a good practice for educating the IT team and other employees on the basic principles and practices of cybersecurity. However, it does not simulate or replicate the real-world situations and challenges that the IT team may face during security incidents. Sharing communications relating to scheduled maintenance is a good practice for informing the IT team and other stakeholders of the planned activities and potential impacts on the IT systems and infrastructure. However, it does not prepare the IT team for dealing with unplanned or unexpected security events that may require immediate and coordinated response.Reference:CISA Tabletop Exercise Packages;Cybersecurity Tabletop Exercise Examples, Best Practices, and Considerations;Six Tabletop Exercises to Help Prepare Your Cybersecurity Team

How are individual program needs and specific organizational goals identified in privacy framework development?

A.

By employing metrics to align privacy protection with objectives.

A.

By employing metrics to align privacy protection with objectives.

Answers
B.

Through conversations with the privacy team.

B.

Through conversations with the privacy team.

Answers
C.

By employing an industry-standard needs analysis.

C.

By employing an industry-standard needs analysis.

Answers
D.

Through creation of the business case.

D.

Through creation of the business case.

Answers
Suggested answer: D

Explanation:

The creation of the business case is the first step in privacy framework development, as it helps to identify the individual program needs and specific organizational goals. The business case is a document that outlines the rationale, objectives, benefits, costs, risks, and alternatives for implementing a privacy program. It also helps to communicate the value of privacy to stakeholders and gain their support. The other options are subsequent steps in privacy framework development, after the business case has been established.Reference:CIPM Study Guide, page 15.

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