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SCENARIO

Please use the following to answer the next QUESTION:

Natalia, CFO of the Nationwide Grill restaurant chain, had never seen her fellow executives so anxious. Last week, a data processing firm used by the company reported that its system may have been hacked, and customer data such as names, addresses, and birthdays may have been compromised. Although the attempt was proven unsuccessful, the scare has prompted several Nationwide Grill executives to Question the company's privacy program at today's meeting.

Alice, a vice president, said that the incident could have opened the door to lawsuits, potentially damaging

Nationwide Grill's market position. The Chief Information Officer (CIO), Brendan, tried to assure her that even if there had been an actual breach, the chances of a successful suit against the company were slim. But Alice remained unconvinced.

Spencer -- a former CEO and currently a senior advisor -- said that he had always warned against the use of contractors for data processing. At the very least, he argued, they should be held contractually liable for telling customers about any security incidents. In his view, Nationwide Grill should not be forced to soil the company name for a problem it did not cause.

One of the business development (BD) executives, Haley, then spoke, imploring everyone to see reason. 'Breaches can happen, despite organizations' best efforts,' she remarked. 'Reasonable preparedness is key.' She reminded everyone of the incident seven years ago when the large grocery chain Tinkerton's had its financial information compromised after a large order of Nationwide Grill frozen dinners. As a long-time BD executive with a solid understanding of Tinkerton's's corporate culture, built up through many years of cultivating relationships, Haley was able to successfully manage the company's incident response.

Spencer replied that acting with reason means allowing security to be handled by the security functions within the company -- not BD staff. In a similar way, he said, Human Resources (HR) needs to do a better job training employees to prevent incidents. He pointed out that Nationwide Grill employees are overwhelmed with posters, emails, and memos from both HR and the ethics department related to the company's privacy program. Both the volume and the duplication of information means that it is often ignored altogether.

Spencer said, 'The company needs to dedicate itself to its privacy program and set regular in-person trainings for all staff once a month.'

Alice responded that the suggestion, while well-meaning, is not practical. With many locations, local HR departments need to have flexibility with their training schedules. Silently, Natalia agreed.

What is the most realistic step the organization can take to help diminish liability in the event of another incident?

A.

Requiring the vendor to perform periodic internal audits.

A.

Requiring the vendor to perform periodic internal audits.

Answers
B.

Specifying mandatory data protection practices in vendor contracts.

B.

Specifying mandatory data protection practices in vendor contracts.

Answers
C.

Keeping the majority of processing activities within the organization.

C.

Keeping the majority of processing activities within the organization.

Answers
D.

Obtaining customer consent for any third-party processing of personal data.

D.

Obtaining customer consent for any third-party processing of personal data.

Answers
Suggested answer: B

Explanation:

This answer is the most realistic step the organization can take to help diminish liability in the event of another incident, as it can ensure that the vendor complies with the same standards and obligations as the organization regarding data protection. Vendor contracts should include clauses that specify the scope, purpose, duration and type of data processing, as well as the rights and responsibilities of both parties. The contracts should also require the vendor to implement appropriate technical and organizational measures to protect the data from unauthorized or unlawful access, use, disclosure, alteration or destruction, and to notify the organization of any security incidents or breaches. The contracts should also allow the organization to monitor, audit or inspect the vendor's performance and compliance with the contract terms and applicable laws and regulations.Reference: IAPP CIPM Study Guide, page 82; ISO/IEC 27002:2013, section 15.1.2

SCENARIO

Please use the following to answer the next QUESTION:

Natalia, CFO of the Nationwide Grill restaurant chain, had never seen her fellow executives so anxious. Last week, a data processing firm used by the company reported that its system may have been hacked, and customer data such as names, addresses, and birthdays may have been compromised. Although the attempt was proven unsuccessful, the scare has prompted several Nationwide Grill executives to Question the company's privacy program at today's meeting.

Alice, a vice president, said that the incident could have opened the door to lawsuits, potentially damaging Nationwide Grill's market position. The Chief Information Officer (CIO), Brendan, tried to assure her that even if there had been an actual breach, the chances of a successful suit against the company were slim. But Alice remained unconvinced.

Spencer -- a former CEO and currently a senior advisor -- said that he had always warned against the use of contractors for data processing. At the very least, he argued, they should be held contractually liable for telling customers about any security incidents. In his view, Nationwide Grill should not be forced to soil the company name for a problem it did not cause.

One of the business development (BD) executives, Haley, then spoke, imploring everyone to see reason. 'Breaches can happen, despite organizations' best efforts,' she remarked. 'Reasonable preparedness is key.' She reminded everyone of the incident seven years ago when the large grocery chain Tinkerton's had its financial information compromised after a large order of Nationwide Grill frozen dinners. As a long-time BD executive with a solid understanding of Tinkerton's's corporate culture, built up through many years of cultivating relationships, Haley was able to successfully manage the company's incident response.

Spencer replied that acting with reason means allowing security to be handled by the security functions within the company -- not BD staff. In a similar way, he said, Human Resources (HR) needs to do a better job training employees to prevent incidents. He pointed out that Nationwide Grill employees are overwhelmed with posters, emails, and memos from both HR and the ethics department related to the company's privacy program. Both the volume and the duplication of information means that it is often ignored altogether.

Spencer said, 'The company needs to dedicate itself to its privacy program and set regular in-person trainings for all staff once a month.'

Alice responded that the suggestion, while well-meaning, is not practical. With many locations, local HR departments need to have flexibility with their training schedules. Silently, Natalia agreed.

Based on the scenario, Nationwide Grill needs to create better employee awareness of the company's privacy program by doing what?

A.

Varying the modes of communication.

A.

Varying the modes of communication.

Answers
B.

Communicating to the staff more often.

B.

Communicating to the staff more often.

Answers
C.

Improving inter-departmental cooperation.

C.

Improving inter-departmental cooperation.

Answers
D.

Requiring acknowledgment of company memos.

D.

Requiring acknowledgment of company memos.

Answers
Suggested answer: A

Explanation:

This answer is the best way to create better employee awareness of the company's privacy program, as it can increase the effectiveness and retention of the information by appealing to different learning styles and preferences. Varying the modes of communication can include using different formats and channels, such as posters, emails, memos, videos, webinars, podcasts, newsletters, quizzes, games or interactive modules. Varying the modes of communication can also help to avoid information overload or duplication, which may cause employees to ignore or disregard the privacy messages.Reference: IAPP CIPM Study Guide, page 90; ISO/IEC 27002:2013, section 7.2.2

SCENARIO

Please use the following to answer the next QUESTION:

Natalia, CFO of the Nationwide Grill restaurant chain, had never seen her fellow executives so anxious. Last week, a data processing firm used by the company reported that its system may have been hacked, and customer data such as names, addresses, and birthdays may have been compromised. Although the attempt was proven unsuccessful, the scare has prompted several Nationwide Grill executives to Question the company's privacy program at today's meeting.

Alice, a vice president, said that the incident could have opened the door to lawsuits, potentially damaging Nationwide Grill's market position. The Chief Information Officer (CIO), Brendan, tried to assure her that even if there had been an actual breach, the chances of a successful suit against the company were slim. But Alice remained unconvinced.

Spencer -- a former CEO and currently a senior advisor -- said that he had always warned against the use of contractors for data processing. At the very least, he argued, they should be held contractually liable for telling customers about any security incidents. In his view, Nationwide Grill should not be forced to soil the company name for a problem it did not cause.

One of the business development (BD) executives, Haley, then spoke, imploring everyone to see reason. 'Breaches can happen, despite organizations' best efforts,' she remarked. 'Reasonable preparedness is key.' She reminded everyone of the incident seven years ago when the large grocery chain Tinkerton's had its financial information compromised after a large order of Nationwide Grill frozen dinners. As a long-time BD executive with a solid understanding of Tinkerton's's corporate culture, built up through many years of cultivating relationships, Haley was able to successfully manage the company's incident response.

Spencer replied that acting with reason means allowing security to be handled by the security functions within the company -- not BD staff. In a similar way, he said, Human Resources (HR) needs to do a better job training employees to prevent incidents. He pointed out that Nationwide Grill employees are overwhelmed with posters, emails, and memos from both HR and the ethics department related to the company's privacy program. Both the volume and the duplication of information means that it is often ignored altogether.

Spencer said, 'The company needs to dedicate itself to its privacy program and set regular in-person trainings for all staff once a month.'

Alice responded that the suggestion, while well-meaning, is not practical. With many locations, local HR departments need to have flexibility with their training schedules. Silently, Natalia agreed.

How could the objection to Spencer's training suggestion be addressed?

A.

By requiring training only on an as-needed basis.

A.

By requiring training only on an as-needed basis.

Answers
B.

By offering alternative delivery methods for trainings.

B.

By offering alternative delivery methods for trainings.

Answers
C.

By introducing a system of periodic refresher trainings.

C.

By introducing a system of periodic refresher trainings.

Answers
D.

By customizing training based on length of employee tenure.

D.

By customizing training based on length of employee tenure.

Answers
Suggested answer: B

Explanation:

This answer is the best way to address the objection to Spencer's training suggestion, as it can provide flexibility and convenience for employees who work in different locations or have different schedules. Alternative delivery methods for trainings can include online courses, webinars, podcasts, videos or self-paced modules that can be accessed anytime and anywhere by employees. Alternative delivery methods can also reduce the cost and time required for in-person trainings, while still ensuring that employees receive consistent and relevant information on the company's privacy program.Reference: IAPP CIPM Study Guide, page 90; ISO/IEC 27002:2013, section 7.2.2

SCENARIO

Please use the following to answer the next QUESTION:

Natalia, CFO of the Nationwide Grill restaurant chain, had never seen her fellow executives so anxious. Last week, a data processing firm used by the company reported that its system may have been hacked, and customer data such as names, addresses, and birthdays may have been compromised. Although the attempt was proven unsuccessful, the scare has prompted several Nationwide Grill executives to Question the company's privacy program at today's meeting.

Alice, a vice president, said that the incident could have opened the door to lawsuits, potentially damaging Nationwide Grill's market position. The Chief Information Officer (CIO), Brendan, tried to assure her that even if there had been an actual breach, the chances of a successful suit against the company were slim. But Alice remained unconvinced.

Spencer -- a former CEO and currently a senior advisor -- said that he had always warned against the use of contractors for data processing. At the very least, he argued, they should be held contractually liable for telling customers about any security incidents. In his view, Nationwide Grill should not be forced to soil the company name for a problem it did not cause.

One of the business development (BD) executives, Haley, then spoke, imploring everyone to see reason.

'Breaches can happen, despite organizations' best efforts,' she remarked. 'Reasonable preparedness is key.' She reminded everyone of the incident seven years ago when the large grocery chain Tinkerton's had its financial information compromised after a large order of Nationwide Grill frozen dinners. As a long-time BD executive with a solid understanding of Tinkerton's's corporate culture, built up through many years of cultivating relationships, Haley was able to successfully manage the company's incident response.

Spencer replied that acting with reason means allowing security to be handled by the security functions within the company -- not BD staff. In a similar way, he said, Human Resources (HR) needs to do a better job training employees to prevent incidents. He pointed out that Nationwide Grill employees are overwhelmed with posters, emails, and memos from both HR and the ethics department related to the company's privacy program. Both the volume and the duplication of information means that it is often ignored altogether.

Spencer said, 'The company needs to dedicate itself to its privacy program and set regular in-person trainings for all staff once a month.'

Alice responded that the suggestion, while well-meaning, is not practical. With many locations, local HR departments need to have flexibility with their training schedules. Silently, Natalia agreed.

The senior advisor, Spencer, has a misconception regarding?

A.

The amount of responsibility that a data controller retains.

A.

The amount of responsibility that a data controller retains.

Answers
B.

The appropriate role of an organization's security department.

B.

The appropriate role of an organization's security department.

Answers
C.

The degree to which training can lessen the number of security incidents.

C.

The degree to which training can lessen the number of security incidents.

Answers
D.

The role of Human Resources employees in an organization's privacy program.

D.

The role of Human Resources employees in an organization's privacy program.

Answers
Suggested answer: A

Explanation:

Spencer has a misconception regarding the amount of responsibility that a data controller retains, as he suggests that the contractors should be held contractually liable for telling customers about any security incidents, and that Nationwide Grill should not be forced to soil the company name for a problem it did not cause. However, as a data controller, Nationwide Grill is ultimately responsible for ensuring that the personal data of its customers is processed in compliance with applicable laws and regulations, regardless of whether it uses contractors or not. Nationwide Grill cannot transfer or delegate its accountability or liability to the contractors, and it has a duty to inform the customers and the relevant authorities of any security incidents or breaches that may affect their data. Therefore, Spencer's view is unrealistic and risky, as it may expose Nationwide Grill to legal actions, fines, reputational damage and loss of trust.

Formosa International operates in 20 different countries including the United States and France. What organizational approach would make complying with a number of different regulations easier?

A.

Data mapping.

A.

Data mapping.

Answers
B.

Fair Information Practices.

B.

Fair Information Practices.

Answers
C.

Rationalizing requirements.

C.

Rationalizing requirements.

Answers
D.

Decentralized privacy management.

D.

Decentralized privacy management.

Answers
Suggested answer: C

Explanation:

Rationalizing requirements is an organizational approach that involves identifying and harmonizing the common elements of different privacy regulations and standards. This can make compliance easier and more efficient, as well as reduce the risk of conflicts or gaps in privacy protection. Rationalizing requirements can also help to create a consistent privacy policy and culture across different jurisdictions and business units.Reference:CIPM Study Guide, page 23.

When implementing Privacy by Design (PbD), what would NOT be a key consideration?

A.

Collection limitation.

A.

Collection limitation.

Answers
B.

Data minimization.

B.

Data minimization.

Answers
C.

Limitations on liability.

C.

Limitations on liability.

Answers
D.

Purpose specification.

D.

Purpose specification.

Answers
Suggested answer: C

Explanation:

Limitations on liability are not a key consideration when implementing Privacy by Design (PbD). PbD is a methodology that aims to protect privacy by embedding it into the design of systems and data. The key considerations for PbD are based on seven principles that include collection limitation, data minimization, and purpose specification, among others. Limitations on liability are more relevant for contractual or legal aspects of privacy, not for design or engineering aspects.Reference:CIPM Study Guide, page 25;The 7 Principles of Privacy by Design.

For an organization that has just experienced a data breach, what might be the least relevant metric for a company's privacy and governance team?

A.

The number of security patches applied to company devices.

A.

The number of security patches applied to company devices.

Answers
B.

The number of privacy rights requests that have been exercised.

B.

The number of privacy rights requests that have been exercised.

Answers
C.

The number of Privacy Impact Assessments that have been completed.

C.

The number of Privacy Impact Assessments that have been completed.

Answers
D.

The number of employees who have completed data awareness training.

D.

The number of employees who have completed data awareness training.

Answers
Suggested answer: A

Explanation:

The number of security patches applied to company devices might be the least relevant metric for a company's privacy and governance team after a data breach. While security patches are important for preventing future breaches, they do not directly measure the impact or response of the current breach. The other metrics are more relevant for assessing how the company handled the breach, such as how it complied with the privacy rights of affected individuals, how it evaluated the privacy risks of its systems, and how it trained its employees on data awareness.Reference:CIPM Study Guide, page 28.

What is the best way to understand the location, use and importance of personal data within an organization?

A.

By analyzing the data inventory.

A.

By analyzing the data inventory.

Answers
B.

By testing the security of data systems.

B.

By testing the security of data systems.

Answers
C.

By evaluating methods for collecting data.

C.

By evaluating methods for collecting data.

Answers
D.

By interviewing employees tasked with data entry.

D.

By interviewing employees tasked with data entry.

Answers
Suggested answer: C

Explanation:

The best way to understand the location, use and importance of personal data within an organization is by evaluating methods for collecting data. This will help to identify the sources, purposes, and categories of data that the organization processes, as well as the data flows and transfers within and outside the organization. By doing so, the organization can assess the risks and opportunities associated with data processing and design appropriate privacy policies and controls.Reference: [IAPP CIPM Study Guide], page 29-30; [Data Inventory]

What are you doing if you succumb to 'overgeneralization' when analyzing data from metrics?

A.

Using data that is too broad to capture specific meanings.

A.

Using data that is too broad to capture specific meanings.

Answers
B.

Possessing too many types of data to perform a valid analysis.

B.

Possessing too many types of data to perform a valid analysis.

Answers
C.

Using limited data in an attempt to support broad conclusions.

C.

Using limited data in an attempt to support broad conclusions.

Answers
D.

Trying to use several measurements to gauge one aspect of a program.

D.

Trying to use several measurements to gauge one aspect of a program.

Answers
Suggested answer: A

Explanation:

If you succumb to ''overgeneralization'' when analyzing data from metrics, you are using data that is too broad to capture specific meanings. For example, if you use a single metric such as ''number of complaints'' to measure customer satisfaction, you are ignoring other factors that may affect customer satisfaction such as quality of service, responsiveness, or loyalty. You are also assuming that all complaints are equally valid and important, which may not be the case. To avoid overgeneralization, you should use multiple metrics that are relevant, specific, and measurable for your objectives.Reference: [IAPP CIPM Study Guide], page 59-60; [Avoiding Overgeneralization in Data Analysis]

In addition to regulatory requirements and business practices, what important factors must a global privacy strategy consider?

A.

Monetary exchange.

A.

Monetary exchange.

Answers
B.

Geographic features.

B.

Geographic features.

Answers
C.

Political history.

C.

Political history.

Answers
D.

Cultural norms.

D.

Cultural norms.

Answers
Suggested answer: D

Explanation:

In addition to regulatory requirements and business practices, an important factor that a global privacy strategy must consider is cultural norms. Different cultures may have different expectations and preferences regarding privacy, such as what constitutes personal information, how consent is obtained and expressed, how data is used and shared, and how privacy rights are enforced. A global privacy strategy should respect and accommodate these cultural differences and ensure that the organization's privacy practices are transparent, fair, and consistent across different regions.Reference: [IAPP CIPM Study Guide], page 81-82; [Cultural Differences in Privacy Expectations]

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