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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.

In terms of compliance with regulatory and legislative changes, Anton has a misconception regarding?

A.

The timeline for monitoring.

A.

The timeline for monitoring.

Answers
B.

The method of recordkeeping.

B.

The method of recordkeeping.

Answers
C.

The use of internal employees.

C.

The use of internal employees.

Answers
D.

The type of required qualifications.

D.

The type of required qualifications.

Answers
Suggested answer: A

Explanation:

In terms of compliance with regulatory and legislative changes, Anton has a misconception regarding the timeline for monitoring. He believes that the company should be safe for another five years after conducting a compliance assessment and documenting the analysis. However, this is a risky and unrealistic assumption that could expose the company to legal liabilities and penalties. Regulatory and legislative changes are dynamic and frequent in today's business environment.They can affect various aspects of the company's operations, such as data protection, online marketing, consumer rights, labor laws, tax laws, environmental laws, etc5Therefore, the company needs to monitor these changes continuously and proactively to ensure compliance at all times. Waiting for five years to check for compliance again could result in missing important updates or requirements that could impact the company's business practices or obligations.Moreover, compliance monitoring is not only a one-time activity but an ongoing process that involves evaluating the effectiveness of the company's policies and procedures in meeting the regulatory standards and expectations6Compliance monitoring also helps to identify any gaps or weaknesses in the company's compliance program and take corrective actions to improve it.Therefore, Anton should revise his timeline for monitoring regulatory and legislative changes and adopt a more regular and systematic approach that aligns with the company's risk profile and regulatory environment.Reference:5: Regulatory Change Management: How To Keep Up With Regulatory Changes;6: Compliance Monitoring - What Is It?

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.

What would the company's legal team most likely recommend to Anton regarding his planned communication with customers?

A.

To send consistent communication.

A.

To send consistent communication.

Answers
B.

To shift to electronic communication.

B.

To shift to electronic communication.

Answers
C.

To delay communications until local authorities are informed.

C.

To delay communications until local authorities are informed.

Answers
D.

To consider under what circumstances communication is necessary.

D.

To consider under what circumstances communication is necessary.

Answers
Suggested answer: D

Explanation:

The company's legal team would most likely recommend Anton to consider under what circumstances communication with customers is necessary after learning of a recent security incident. Communication with customers is an important aspect of data breach response as it can help to mitigate the harm caused by the breach, restore trust and confidence in the company, and comply with legal obligations or best practices.However, communication with customers is not always mandatory or advisable depending on the nature and severity of the breach and the potential impact on the customers7Therefore, Anton should consult with his legal team and evaluate the following factors before deciding whether to communicate with customers or not:

The type and amount of data involved in the breach and whether it includes personal or sensitive information that could expose the customers to identity theft, fraud, or other harms.

The likelihood and extent of harm that the customers could suffer as a result of the breach and whether they could take any actions to prevent or reduce it.

The legal or contractual obligations that the company has to notify the customers or the relevant authorities about the breach and the applicable laws or regulations that govern the notification process, such as the timing, content, and method of notification.

The potential benefits and risks of communicating with customers, such as enhancing transparency and accountability, providing assistance and remedies, or triggering negative reactions, reputational damage, or legal claims.

Based on these factors, Anton should determine whether communication with customers is necessary and appropriate in his case. If he decides to communicate with customers, he should follow some best practices, such as:

Communicating as soon as possible after discovering and containing the breach and having sufficient information to share.

Communicating clearly, honestly, and empathetically about what happened, what data was affected, what actions the company has taken or will take, and what steps the customers can or should take.

Communicating through multiple channels, such as email, phone, letter, website, or social media, depending on the preferences and expectations of the customers.

Communicating consistently and regularly with updates or follow-ups until the breach is resolved and the customers are satisfied8

Why were the nongovernmental privacy organizations, Electronic Frontier Foundation (EFF) and Electronic Privacy Information Center (EPIC), established?

A.

To promote consumer confidence in the Internet industry.

A.

To promote consumer confidence in the Internet industry.

Answers
B.

To improve the user experience during online shopping.

B.

To improve the user experience during online shopping.

Answers
C.

To protect civil liberties and raise consumer awareness.

C.

To protect civil liberties and raise consumer awareness.

Answers
D.

To promote security on the Internet through strong encryption.

D.

To promote security on the Internet through strong encryption.

Answers
Suggested answer: C

Explanation:

The nongovernmental privacy organizations, Electronic Frontier Foundation (EFF) and Electronic Privacy Information Center (EPIC), were established to protect civil liberties and raise consumer awareness in the digital age.Both organizations are public interest research centers that focus on emerging privacy and civil liberties issues and advocate for the protection of privacy, freedom of expression, and democratic values in the information age12They conduct policy research, public education, litigation, publications, and advocacy to promote privacy rights and challenge threats to privacy from governments, corporations, or other actors12They also monitor and participate in the development of laws, regulations, standards, and technologies that affect privacy and civil liberties12Reference:1:About EPIC;2:About EFF

What is the main function of the Asia-Pacific Economic Cooperation Privacy Framework?

A.

Enabling regional data transfers.

A.

Enabling regional data transfers.

Answers
B.

Protecting data from parties outside the region.

B.

Protecting data from parties outside the region.

Answers
C.

Establishing legal requirements for privacy protection in the region.

C.

Establishing legal requirements for privacy protection in the region.

Answers
D.

Marketing privacy protection technologies developed in the region.

D.

Marketing privacy protection technologies developed in the region.

Answers
Suggested answer: A

Explanation:

The main function of the Asia-Pacific Economic Cooperation Privacy Framework is enabling regional data transfers while protecting information privacy across APEC member economies.The Framework promotes a flexible approach to information privacy protection that avoids the creation of unnecessary barriers to information flows3It is based on a set of common privacy principles that are consistent with the core values of the OECD Guidelines on the Protection of Privacy and Transborder Flows of Personal Data3The Framework also provides guidance for domestic implementation and international implementation of the privacy principles through various mechanisms, such as cross-border privacy rules (CBPRs), accountability agents, regulators, enforcement cooperation, and capacity building3The Framework aims to facilitate the safe transfer of information between economies, enhance consumer trust and confidence in online transactions and information networks, encourage the use of electronic data to enhance and expand business opportunities, and provide technical assistance to economies that have yet to address privacy from a regulatory or policy perspective4Reference:3:APEC PRIVACY PRINCIPLES;4:APEC Data Privacy Pathfinder

Which of the following is TRUE about the Data Protection Impact Assessment (DPIA) process as required under the General Data Protection Regulation (GDPR)?

A.

The DPIA result must be reported to the corresponding supervisory authority.

A.

The DPIA result must be reported to the corresponding supervisory authority.

Answers
B.

The DPIA report must be published to demonstrate the transparency of the data processing.

B.

The DPIA report must be published to demonstrate the transparency of the data processing.

Answers
C.

The DPIA must include a description of the proposed processing operation and its purpose.

C.

The DPIA must include a description of the proposed processing operation and its purpose.

Answers
D.

The DPIA is required if the processing activity entails risk to the rights and freedoms of an EU individual.

D.

The DPIA is required if the processing activity entails risk to the rights and freedoms of an EU individual.

Answers
Suggested answer: C

Explanation:

The statement that is true about the Data Protection Impact Assessment (DPIA) process as required under the General Data Protection Regulation (GDPR) is that the DPIA must include a description of the proposed processing operation and its purpose. According to Article 35(7) of the GDPR, a DPIA shall contain at least:

''a systematic description of the envisaged processing operations and the purposes of the processing'';

''an assessment of the necessity and proportionality of the processing operations in relation to the purposes'';

''an assessment of the risks to the rights and freedoms of data subjects'';

''the measures envisaged to address the risks'';

''safeguards'', ''security measures'';

''mechanisms to ensure the protection of personal data'';

''to demonstrate compliance with this Regulation taking into account the rights and legitimate interests of data subjects and other persons concerned''5

Therefore, a DPIA must include a description of what data processing activities are planned and why they are needed as part of its content.This helps to provide a clear overview of the processing operation and its objectives as well as to assess its necessity and proportionality in relation to its purposes6Reference:5: [General Data Protection Regulation (GDPR) -- Official Legal Text], Article 35(7);6: Data protection impact assessments | ICO

As a Data Protection Officer, one of your roles entails monitoring changes in laws and regulations and updating policies accordingly.

How would you most effectively execute this responsibility?

A.

Consult an external lawyer.

A.

Consult an external lawyer.

Answers
B.

Regularly engage regulators.

B.

Regularly engage regulators.

Answers
C.

Attend workshops and interact with other professionals.

C.

Attend workshops and interact with other professionals.

Answers
D.

Subscribe to email list-serves that report on regulatory changes.

D.

Subscribe to email list-serves that report on regulatory changes.

Answers
Suggested answer: D

Explanation:

As a Data Protection Officer (DPO), one of the most effective ways to execute your responsibility of monitoring changes in laws and regulations and updating policies accordingly is to subscribe to email list-serves that report on regulatory changes.Email list-serves are online mailing lists that allow subscribers to receive regular updates on topics or issues of interest via email7By subscribing to email list-serves that report on regulatory changes, you can stay informed of the latest developments and trends in the regulatory environment that affect your organization and its data protection practices.You can also access relevant information and resources from reliable sources, such as regulatory agencies, law firms, industry associations, or experts8This can help you to identify and analyze the impact of regulatory changes on your organization and its data processing activities, and to update your policies and procedures accordingly to ensure compliance8Some examples of email list-serves that report on regulatory changes are:

The ICO Newsletter: This is a monthly newsletter from the UK Information Commissioner's Office (ICO) that provides updates on data protection news, guidance, events, consultations, and enforcement actions9

The Privacy Advisor: This is a monthly newsletter from the International Association of Privacy Professionals (IAPP) that covers global privacy news, analysis, and insights10

The Privacy & Data Security Law Journal: This is a monthly journal from LexisNexis that provides articles and case notes on privacy and data security law issues from around the world11

The Data Protection Report: This is a blog from Norton Rose Fulbright that provides updates and commentary on data protection and cybersecurity developments across various jurisdictions12

SCENARIO

Please use the following to answer the next QUESTION:

John is the new privacy officer at the prestigious international law firm -- A&M LLP. A&M LLP is very proud of its reputation in the practice areas of Trusts & Estates and Merger & Acquisition in both U.S. and Europe.

During lunch with a colleague from the Information Technology department, John heard that the Head of IT, Derrick, is about to outsource the firm's email continuity service to their existing email security vendor -- MessageSafe. Being successful as an email hygiene vendor, MessageSafe is expanding its business by leasing cloud infrastructure from Cloud Inc. to host email continuity service for A&M LLP.

John is very concerned about this initiative. He recalled that MessageSafe was in the news six months ago due to a security breach. Immediately, John did a quick research of MessageSafe's previous breach and learned that the breach was caused by an unintentional mistake by an IT administrator. He scheduled a meeting with Derrick to address his concerns.

At the meeting, Derrick emphasized that email is the primary method for the firm's lawyers to communicate with clients, thus it is critical to have the email continuity service to avoid any possible email downtime. Derrick has been using the anti-spam service provided by MessageSafe for five years and is very happy with the quality of service provided by MessageSafe. In addition to the significant discount offered by MessageSafe, Derrick emphasized that he can also speed up the onboarding process since the firm already has a service contract in place with MessageSafe. The existing on-premises email continuity solution is about to reach its end of life very soon and he doesn't have the time or resource to look for another solution. Furthermore, the off-premises email continuity service will only be turned on when the email service at A&M LLP's primary and secondary data centers are both down, and the email messages stored at MessageSafe site for continuity service will be automatically deleted after 30 days.

Which of the following is the most effective control to enforce MessageSafe's implementation of appropriate technical countermeasures to protect the personal data received from A&M LLP?

A.

MessageSafe must apply due diligence before trusting Cloud Inc. with the personal data received from A&M LLP.

A.

MessageSafe must apply due diligence before trusting Cloud Inc. with the personal data received from A&M LLP.

Answers
B.

MessageSafe must flow-down its data protection contract terms with A&M LLP to Cloud Inc.

B.

MessageSafe must flow-down its data protection contract terms with A&M LLP to Cloud Inc.

Answers
C.

MessageSafe must apply appropriate security controls on the cloud infrastructure.

C.

MessageSafe must apply appropriate security controls on the cloud infrastructure.

Answers
D.

MessageSafe must notify A&M LLP of a data breach.

D.

MessageSafe must notify A&M LLP of a data breach.

Answers
Suggested answer: C

Explanation:

The most effective control to enforce MessageSafe's implementation of appropriate technical countermeasures to protect the personal data received from A&M LLP is to require MessageSafe to apply appropriate security controls on the cloud infrastructure. This control ensures that MessageSafe takes responsibility for securing the personal data that it processes on behalf of A&M LLP on the cloud platform provided by Cloud Inc.According to the GDPR, data processors must implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of processing personal data1These measures may include encryption, pseudonymisation, access control, backup and recovery, logging and monitoring, vulnerability management, incident response, etc2Furthermore, data processors must ensure that any sub-processors they engage to process personal data on behalf of the data controller also comply with the same obligations3Therefore, MessageSafe must ensure that Cloud Inc. provides adequate security guarantees for the cloud infrastructure and services that it uses to host the email continuity service for A&M LLP. MessageSafe must also monitor and audit the security performance of Cloud Inc.and report any issues or breaches to A&M LLP.Reference:1:Article 32 GDPR | General Data Protection Regulation (GDPR);2:Guidelines 4/2019 on Article 25 Data Protection by Design and by Default | European Data Protection Board;3:Article 28 GDPR | General Data Protection Regulation (GDPR)

SCENARIO

Please use the following to answer the next QUESTION:

John is the new privacy officer at the prestigious international law firm -- A&M LLP. A&M LLP is very proud of its reputation in the practice areas of Trusts & Estates and Merger & Acquisition in both U.S. and Europe.

During lunch with a colleague from the Information Technology department, John heard that the Head of IT, Derrick, is about to outsource the firm's email continuity service to their existing email security vendor -- MessageSafe. Being successful as an email hygiene vendor, MessageSafe is expanding its business by leasing cloud infrastructure from Cloud Inc. to host email continuity service for A&M LLP.

John is very concerned about this initiative. He recalled that MessageSafe was in the news six months ago due to a security breach. Immediately, John did a quick research of MessageSafe's previous breach and learned that the breach was caused by an unintentional mistake by an IT administrator. He scheduled a meeting with Derrick to address his concerns.

At the meeting, Derrick emphasized that email is the primary method for the firm's lawyers to communicate with clients, thus it is critical to have the email continuity service to avoid any possible email downtime. Derrick has been using the anti-spam service provided by MessageSafe for five years and is very happy with the quality of service provided by MessageSafe. In addition to the significant discount offered by MessageSafe, Derrick emphasized that he can also speed up the onboarding process since the firm already has a service contract in place with MessageSafe. The existing on-premises email continuity solution is about to reach its end of life very soon and he doesn't have the time or resource to look for another solution. Furthermore, the off- premises email continuity service will only be turned on when the email service at A&M LLP's primary and secondary data centers are both down, and the email messages stored at MessageSafe site for continuity service will be automatically deleted after 30 days.

Which of the following is a TRUE statement about the relationship among the organizations?

A.

Cloud Inc. must notify A&M LLP of a data breach immediately.

A.

Cloud Inc. must notify A&M LLP of a data breach immediately.

Answers
B.

MessageSafe is liable if Cloud Inc. fails to protect data from A&M LLP.

B.

MessageSafe is liable if Cloud Inc. fails to protect data from A&M LLP.

Answers
C.

Cloud Inc. should enter into a data processor agreement with A&M LLP.

C.

Cloud Inc. should enter into a data processor agreement with A&M LLP.

Answers
D.

A&M LLP's service contract must be amended to list Cloud Inc. as a sub-processor.

D.

A&M LLP's service contract must be amended to list Cloud Inc. as a sub-processor.

Answers
Suggested answer: B

Explanation:

A true statement about the relationship among the organizations is that MessageSafe is liable if Cloud Inc. fails to protect data from A&M LLP.This statement reflects the principle of accountability under the GDPR, which requires data controllers and processors to be responsible for complying with the GDPR and demonstrating their compliance4As a data processor for A&M LLP, MessageSafe is liable for any damage caused by processing that infringes the GDPR or by processing that does not comply with A&M LLP's lawful instructions5This liability extends to any sub-processors that MessageSafe engages to carry out specific processing activities on behalf of A&M LLP5Therefore, if Cloud Inc., as a sub-processor for MessageSafe, fails to protect data from A&M LLP and causes harm to the data subjects or breaches the GDPR or A&M LLP's instructions, MessageSafe will be held liable for such failure and may have to pay compensation or face administrative fines or other sanctions6Reference:4:Article 5 GDPR | General Data Protection Regulation (GDPR);5:Article 82 GDPR | General Data Protection Regulation (GDPR);6:Article 83 GDPR | General Data Protection Regulation (GDPR)

SCENARIO

Please use the following to answer the next QUESTION:

John is the new privacy officer at the prestigious international law firm -- A&M LLP. A&M LLP is very proud of its reputation in the practice areas of Trusts & Estates and Merger & Acquisition in both U.S. and Europe.

During lunch with a colleague from the Information Technology department, John heard that the Head of IT, Derrick, is about to outsource the firm's email continuity service to their existing email security vendor -- MessageSafe. Being successful as an email hygiene vendor, MessageSafe is expanding its business by leasing cloud infrastructure from Cloud Inc. to host email continuity service for A&M LLP.

John is very concerned about this initiative. He recalled that MessageSafe was in the news six months ago due to a security breach. Immediately, John did a quick research of MessageSafe's previous breach and learned that the breach was caused by an unintentional mistake by an IT administrator. He scheduled a meeting with Derrick to address his concerns.

At the meeting, Derrick emphasized that email is the primary method for the firm's lawyers to communicate with clients, thus it is critical to have the email continuity service to avoid any possible email downtime. Derrick has been using the anti-spam service provided by MessageSafe for five years and is very happy with the quality of service provided by MessageSafe. In addition to the significant discount offered by MessageSafe, Derrick emphasized that he can also speed up the onboarding process since the firm already has a service contract in place with MessageSafe. The existing on-premises email continuity solution is about to reach its end of life very soon and he doesn't have the time or resource to look for another solution. Furthermore, the off- premises email continuity service will only be turned on when the email service at A&M LLP's primary and secondary data centers are both down, and the email messages stored at MessageSafe site for continuity service will be automatically deleted after 30 days.

Which of the following is NOT an obligation of MessageSafe as the email continuity service provider for A&M LLP?

A.

Privacy compliance.

A.

Privacy compliance.

Answers
B.

Security commitment.

B.

Security commitment.

Answers
C.

Certifications to relevant frameworks.

C.

Certifications to relevant frameworks.

Answers
D.

Data breach notification to A&M LLP.

D.

Data breach notification to A&M LLP.

Answers
Suggested answer: C

Explanation:

An obligation that is not applicable to MessageSafe as the email continuity service provider for A&M LLP is obtaining certifications to relevant frameworks.Certifications are voluntary mechanisms that enable data controllers or processors to demonstrate their compliance with the GDPR or other standards by obtaining a certification issued by an accredited certification body7Certifications can provide benefits such as enhancing transparency, accountability, trust, and competitive advantage for data controllers or processors.However, they are not mandatory under the GDPR or other laws and do not reduce or eliminate the legal obligations or liabilities of data controllers or processors8Therefore, MessageSafe is not obliged to obtain certifications to relevant frameworks as the email continuity service provider for A&M LLP.However, it may choose to do so if it wishes to showcase its compliance efforts or gain a competitive edge in the market.Reference:7:Article 42 GDPR | General Data Protection Regulation (GDPR);8:Guidelines 1/2018 on certification and identifying certification criteria in accordance with Articles 42 and 43 of the Regulation 2016/679 | European Data Protection Board

In privacy protection, what is a 'covered entity'?

A.

Personal data collected by a privacy organization.

A.

Personal data collected by a privacy organization.

Answers
B.

An organization subject to the privacy provisions of HIPAA.

B.

An organization subject to the privacy provisions of HIPAA.

Answers
C.

A privacy office or team fully responsible for protecting personal information.

C.

A privacy office or team fully responsible for protecting personal information.

Answers
D.

Hidden gaps in privacy protection that may go unnoticed without expert analysis.

D.

Hidden gaps in privacy protection that may go unnoticed without expert analysis.

Answers
Suggested answer: B

Explanation:

A covered entity is an organization that is subject to the privacy provisions of the Health Insurance Portability and Accountability Act (HIPAA) of 1996. HIPAA regulates how covered entities use and disclose protected health information (PHI) of individuals. Covered entities include health plans, health care clearinghouses, and health care providers that transmit health information electronically.Reference: [HIPAA for Professionals], [What is a Covered Entity?]

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