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Question 21

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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?

Requiring the vendor to perform periodic internal audits.

Requiring the vendor to perform periodic internal audits.

Specifying mandatory data protection practices in vendor contracts.

Specifying mandatory data protection practices in vendor contracts.

Keeping the majority of processing activities within the organization.

Keeping the majority of processing activities within the organization.

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

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

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

asked 22/11/2024
Arvind Prasad S
47 questions

Question 22

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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.

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

Varying the modes of communication.

Varying the modes of communication.

Communicating to the staff more often.

Communicating to the staff more often.

Improving inter-departmental cooperation.

Improving inter-departmental cooperation.

Requiring acknowledgment of company memos.

Requiring acknowledgment of company memos.

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

asked 22/11/2024
samir Heniche
42 questions

Question 23

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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.

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

By requiring training only on an as-needed basis.

By requiring training only on an as-needed basis.

By offering alternative delivery methods for trainings.

By offering alternative delivery methods for trainings.

By introducing a system of periodic refresher trainings.

By introducing a system of periodic refresher trainings.

By customizing training based on length of employee tenure.

By customizing training based on length of employee tenure.

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

asked 22/11/2024
Fthcx Fgghn
40 questions

Question 24

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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.

The senior advisor, Spencer, has a misconception regarding?

The amount of responsibility that a data controller retains.

The amount of responsibility that a data controller retains.

The appropriate role of an organization's security department.

The appropriate role of an organization's security department.

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

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

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

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

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.

asked 22/11/2024
Reydel Tabares Castro
52 questions

Question 25

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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?

Data mapping.

Data mapping.

Fair Information Practices.

Fair Information Practices.

Rationalizing requirements.

Rationalizing requirements.

Decentralized privacy management.

Decentralized privacy management.

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.

asked 22/11/2024
Yannik Huith blu Systems GmbH
36 questions

Question 26

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

Collection limitation.

Collection limitation.

Data minimization.

Data minimization.

Limitations on liability.

Limitations on liability.

Purpose specification.

Purpose specification.

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.

asked 22/11/2024
Serhan Azdiken
47 questions

Question 27

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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?

The number of security patches applied to company devices.

The number of security patches applied to company devices.

The number of privacy rights requests that have been exercised.

The number of privacy rights requests that have been exercised.

The number of Privacy Impact Assessments that have been completed.

The number of Privacy Impact Assessments that have been completed.

The number of employees who have completed data awareness training.

The number of employees who have completed data awareness training.

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.

asked 22/11/2024
victoria nagy
42 questions

Question 28

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

By analyzing the data inventory.

By analyzing the data inventory.

By testing the security of data systems.

By testing the security of data systems.

By evaluating methods for collecting data.

By evaluating methods for collecting data.

By interviewing employees tasked with data entry.

By interviewing employees tasked with data entry.

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]

asked 22/11/2024
Ricardo de SÑ Carvalho
45 questions

Question 29

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

Using data that is too broad to capture specific meanings.

Using data that is too broad to capture specific meanings.

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

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

Using limited data in an attempt to support broad conclusions.

Using limited data in an attempt to support broad conclusions.

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

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

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]

asked 22/11/2024
Musaddiq Shorunke
48 questions

Question 30

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

Monetary exchange.

Monetary exchange.

Geographic features.

Geographic features.

Political history.

Political history.

Cultural norms.

Cultural norms.

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]

asked 22/11/2024
Kefash White
44 questions
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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 practice would afford the Director the most rigorous way to check on the program's compliance with laws, regulations and industry best practices?



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?





SCENARIO Please use the following to answer the next QUESTION: Edufox has hosted an annual convention of users of its famous e-learning software platform, and over time, it has become a grand event. It fills one of the large downtown conference hotels and overflows into the others, with several thousand attendees enjoying three days of presentations, panel discussions and networking. The convention is the centerpiece of the company's product rollout schedule and a great training opportunity for current users. The sales force also encourages prospective clients to attend to get a better sense of the ways in which the system can be customized to meet diverse needs and understand that when they buy into this system, they are joining a community that feels like family. This year's conference is only three weeks away, and you have just heard news of a new initiative supporting it: a smartphone app for attendees. The app will support late registration, highlight the featured presentations and provide a mobile version of the conference program. It also links to a restaurant reservation system with the best cuisine in the areas featured. 'It's going to be great,' the developer, Deidre Hoffman, tells you, 'if, that is, we actually get it working!' She laughs nervously but explains that because of the tight time frame she'd been given to build the app, she outsourced the job to a local firm. 'It's just three young people,' she says, 'but they do great work.' She describes some of the other apps they have built. When asked how they were selected for this job, Deidre shrugs. 'They do good work, so I chose them.' Deidre is a terrific employee with a strong track record. That's why she's been charged to deliver this rushed project. You're sure she has the best interests of the company at heart, and you don't doubt that she's under pressure to meet a deadline that cannot be pushed back. However, you have concerns about the app's handling of personal data and its security safeguards. Over lunch in the break room, you start to talk to her about it, but she quickly tries to reassure you, 'I'm sure with your help we can fix any security issues if we have to, but I doubt there'll be any. These people build apps for a living, and they know what they're doing. You worry too much, but that's why you're so good at your job!' Since it is too late to restructure the contract with the vendor or prevent the app from being deployed, what is the best step for you to take next?

SCENARIO Please use the following to answer the next QUESTION: Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner, Anton, has found some degree of disorganization after touring the company headquarters. His uncle Henry had always focused on production -- not data processing -- and Anton is concerned. In several storage rooms, he has found paper files, disks, and old computers that appear to contain the personal data of current and former employees and customers. Anton knows that a single break-in could irrevocably damage the company's relationship with its loyal customers. He intends to set a goal of guaranteed zero loss of personal information. To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of the company. However, Kenneth -- his uncle's vice president and longtime confidante -- wants to hold off on Anton's idea in favor of converting any paper records held at the company to electronic storage. Kenneth believes this process would only take one or two years. Anton likes this idea; he envisions a password- protected system that only he and Kenneth can access. Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier, but it will simplify the management of the stored data. The heads of subsidiaries like the art gallery and kitchenware store down the street will be responsible for their own information management. Then, any unneeded subsidiary data still in Anton's possession can be destroyed within the next few years. After learning of a recent security incident, Anton realizes that another crucial step will be notifying customers. Kenneth insists that two lost hard drives in Question are not cause for concern; all of the data was encrypted and not sensitive in nature. Anton does not want to take any chances, however. He intends on sending notice letters to all employees and customers to be safe. Anton must also check for compliance with all legislative, regulatory, and market requirements related to privacy protection. Kenneth oversaw the development of the company's online presence about ten years ago, but Anton is not confident about his understanding of recent online marketing laws. Anton is assigning another trusted employee with a law background the task of the compliance assessment. After a thorough analysis, Anton knows the company should be safe for another five years, at which time he can order another check. Documentation of this analysis will show auditors due diligence. Anton has started down a long road toward improved management of the company, but he knows the effort is worth it. Anton wants his uncle's legacy to continue for many years to come. To improve the facility's system of data security, Anton should consider following through with the plan for which of the following?